PraxiChain
PraxiChain
ACTION REQUIRED:
Next Deadline: November 18

COMMENTS & CONDITIONS DUE

The Notice of Intent window closed September 30. The next filing deadline matters most: comments, protests, and requests for conditions in STB Docket FD 36873 are due November 18. That is where shippers get their concerns and the conditions they need into the record. A strong filing needs lane-level data, service history, and a specific ask list.

UP–NS Merger Advisory Center | STB Docket FD 36873

The Railroad Merger That
Changes Everything.
Are You Ready?

When two of America’s largest Class I railroads combine into the first true coast-to-coast network, your freight rates, service reliability, and competitive leverage are on the table. The STB review is now in its substantive phase, and what shippers file in the next seven weeks will shape the conditions the Board imposes. PraxiChain’s rail industry veterans know exactly what that means, and what to do about it.

What's Happening

The Biggest Rail Restructuring in a Generation

On April 30, 2026, Union Pacific and Norfolk Southern refiled their application with the Surface Transportation Board to create the first U.S. transcontinental railroad, a combined network spanning 50,000 route miles across 43 states. On May 28, the STB accepted the revised application but held proceedings in abeyance and ordered supplemental information, which UP and NS filed on July 7 and July 27. On August 18, the Board lifted the abeyance and adopted a full procedural schedule. Notices of Intent to Participate closed on September 30, after an extension from the original September 4 date. The case is now in its substantive phase.

History has a pattern here. The UP–SP integration and the CP–KCS merger both triggered system-wide service meltdowns — on-time performance collapsed to 26% in the aftermath of each. The CSX-Conrail split reshaped Eastern rail competition in ways shippers are still navigating today. The UP–NS transaction is larger and more structurally complex than any of them.

The next deadline is the one that counts. Comments, protests, and requests for conditions are due November 18, 2026. That filing is the main way shippers put evidence and specific asks on the record. Responses and rebuttals follow through Spring 2027, and a final ruling is expected late 2027. The conditions the Board imposes will be drawn largely from what parties file by November 18.

50K
Route miles in combined network across 43 states
4
Prior mergers our team has worked through — from both sides
30+
Years of Class I carrier and shipper-side rail experience
Nov 18
Deadline for comments and requests for conditions
Merger Timeline

Key Dates & Milestones

On August 18, 2026, the STB removed the proceedings from abeyance and issued a full procedural schedule running through 2027. The Notice of Intent window closed on September 30. Next up: comments and requests for conditions, due November 18.

Apr 30, 2026
Revised Application Filed

UP and NS submit a corrected 7,000+ page application addressing January 2026 STB rejection.

May 28, 2026
Completeness Decision

STB accepted the revised application but held proceedings in abeyance pending supplemental information, which UP and NS filed on July 7 and July 27, along with a customer protection package.

Aug 18, 2026
Procedural Schedule Adopted

The STB removed the merger proceedings from abeyance and adopted a full procedural schedule.

Sep 30, 2026
NOI Deadline Closed

Notices of Intent to Participate were due. Parties who filed are on the service list and can submit comments, request conditions, and participate in the evidentiary record.

Nov 18, 2026
NEXT: Comments & Conditions Deadline

Comments, protests, requests for conditions, and responsive applications are due. This is the primary opportunity for shippers to put concerns and required conditions on the record. Responses and rebuttals follow through March 29, 2027.

Early 2027
Evidentiary Phase

Discovery, expert testimony, and data-backed evidence on competitive impacts.

Final decision expected in late 2027. Board approves, denies, or approves with conditions. Your leverage ends here if you haven’t engaged.

Your Exposure

What This Merger Means for You

The case is public: UP and NS are defending the deal directly, projecting $3.5 billion in annual shipper savings, while BNSF, CPKC, and rail labor are pushing back just as hard. None of that decides your outcome. What decides it is the evidence and conditions you put in the docket by November 18. Here’s what each stakeholder group should build its case around.

Rail Shippers
Expect reduced rule 11 leverage, fewer competitive gateway options, and compressed negotiating power on key lanes. The merged carrier will dominate corridors where UP and NS currently compete. Companies with significant captive rail spend face the greatest rate risk. BNSF disputes that the merger's new protections meaningfully change a combined carrier's roughly 50% market share, and CPKC has called the deal 'monopolistic-like' — the leverage questions those disputes raise are exactly what your November 18 comments should answer, using your own lane data.
Short Lines & Regionals
When a carrier can offer a single-line move from Los Angeles to Atlanta, the case for handing traffic to a short line at an interchange weakens fast. Regional carriers need to know exactly which lanes are exposed to single-line substitution — before the merged carrier's commercial team figures it out first. For November 18, identify interchange lanes at risk of single-line substitution and request specific interchange protections.
Ports, Terminals & Transloads
A transcontinental system optimizes for its highest-volume corridors. Ports and terminals off those corridors — or dependent on interchange connections to reach them — are most vulnerable. The key question: what happens to your car supply and frequency commitments when one carrier controls both ends of the move? For November 18, document current car supply and frequency, asking for commitments that hold after consolidation.
Chemical & Industrial Shippers
Among the most exposed groups. Captive movements of hazmat commodities leave little ability to shift modes. The American Chemistry Council and multiple chemical trade groups have already filed in opposition — and independent analysts are now challenging UP-NS's own numbers, including the headline claim of 2.2 million truckloads diverted from highways, which still lacks lane-level detail. For November 18, tie captive hazmat lanes to specific rate and service conditions, and challenge diversion claims with your own movement data.
Agricultural Shippers
Farm bureau and ag trade groups are deeply divided. The risk is real: consolidation of grain and fertilizer corridors, reduced rail-to-rail competition at key export gateways, and longer dwell times that raise carrying costs for perishable and time-sensitive commodities. For November 18, quantify export-gateway and dwell-time exposure by corridor, and request competitive access conditions where rail-to-rail options disappear.
Energy & Utilities
Coal unit train operations, crude oil moves, and LNG feedstock logistics are all affected. The merger may create efficiency gains on some corridors, but only parties with conditions on the record by November 18 will be positioned to secure those benefits.
Why PraxiChain

Merger Experience That Can’t Be Faked

Our team has sat at these tables before — as carrier executives, shipper advocates, and regulatory practitioners. That inside knowledge is your strategic edge.

01
Carrier-Side Fluency

Our consultants include former AVPs and directors from BNSF, UP, NS, and KCS. We know exactly how merger teams think, what they protect, and where they have room to move.

02
STB Process Navigation

The NOI got you in the room. Now the record gets built. We guide shippers and stakeholders through comments, condition requests, and evidentiary filings, so your November 18 submission is specific, data-backed, and hard to ignore.

03
Commercial Contract Leverage

Our team has negotiated millions of dollars in North American rail freight contracts. We know how to build an ask list that delivers results and how to time it against the merger schedule for maximum leverage.

Our Rail Team

The People in Your Corner

PraxiChain’s rail practice draws on decades of carrier, regulatory, and shipper-side experience.

Rail Industry Expert & Merger Lead
Former AVP, BNSF Railway — has worked through prior Class I mergers from the inside
Rail Freight Strategy
Deep expertise in rail contract negotiation and fleet optimization for industrial shippers
Port & Terminal Operations
Former Director of Port Operations, LA/LB; BNSF Railway — rail-port interface expertise
Project Management
Women in Rail Innovation Award recipient; complex multi-stakeholder project delivery
Supply Chain & Logistics
Industrial supply chain design and transformation across rail-dependent sectors
Project Manager
Multimodal bulk commodity logistics; rail, barge, and vessel network optimization; due diligence market analysis
Our Approach

From Assessment to Advocacy

Every shipper’s exposure is different. We start with your specific footprint and build a strategy from there.

01

Merger Exposure Assessment

Complete audit of your current rail operations, contracts, and competitive dependencies across UP and NS networks. We identify where you’re captive, where you have leverage, and what the merger changes.

02

Strategy & Ask List Development

Build your customized list of service commitments, rate protections, and operational guarantees to request as conditions by November 18, and pursue them directly with the merged carrier. We help you quantify and articulate your value.

03

Regulatory Participation

Guide you through every formal step after the NOI: written comments and requests for conditions due November 18, evidentiary submissions, and responses through 2027. Our process knowledge keeps your voice in front of decision-makers through the final ruling.

Take Action Now

Filed Your NOI? Here’s What Comes Next

The Notice of Intent window closed September 30. If you filed, you’re a party of record, and your next filing carries the most weight. Comments, protests, and requests for conditions are due November 18, 2026. If you missed the NOI deadline, talk to us or to the STB’s Rail Customer and Public Assistance office (1-866-254-1792) about your options.

What A Strong November 18 Filing Includes

01
Your exposure, in numbers. Lanes, volumes, and annual rail spend on UP and NS, plus where you are captive today and where you have competitive options.
02
Service history. On-time performance, dwell, car supply, and switch frequency on your key lanes, recorded now so any post-merger decline can be shown against a baseline.
03
A specific ask list. The conditions you want the Board to impose: rate protections, gateway and interchange access, service commitments, reporting requirements.
04
A response to applicants’ claims. Where UP and NS’s diversion, savings, or service projections don’t match your lanes, show it with your own data.
05
A clean filing. Formatted, verified where required, and served on parties of record before submission.
Resources

Stay Informed. Stay in the Proceeding.

Key filings, analysis, and tools to track the merger from announcement through final ruling.

STB Docket
Official FD 36873 Filings

All official STB decisions, procedural orders, and party filings are publicly available on the STB docket. 

PraxiChain Analysis
Rail Merger Impact Analysis

PraxiChain’s 18-page analysis covers competitive impacts, corridor-by-corridor risk, and strategic options for shippers across commodity groups.

Articles
The $1.4 Billion Question in the Merger

Karen Burchfield, former AVP of BNSF, asks whether the merged railroad can meet about $1.4 billion a year in fixed obligations if projected growth doesn’t materialize, and what that sensitivity means for shippers seeking conditions.

Article
A New Generation’s Take on Consolidation

PraxiChain explores the merger with Steve Truitt, former VP and Chief Transportation Officer of KCS — opportunities amid the upheaval.

Podcast
Logistics Matters with DC Velocity

PraxiChain Principal James Shefelbine discusses the pros and cons of the merger for shippers in this DC Velocity podcast episode.

External Resource
STB Rail Customer Assistance

The STB’s Rail Customer Public Assistance program helps rail customers navigate the regulatory process at no cost. Call 1-866-254-1792 or email rcpa@stb.gov.

Request a Merger Readiness Consultation

Whether you need to prepare November 18 comments, build a conditions list, or understand your rate exposure, PraxiChain’s rail team is ready. Consultations are confidential and tailored to your specific commodity, geography, and rail spend.

The shippers who put specific asks on the record by November 18 will shape the terms of this merger. Those who don’t will accept whatever terms they’re given.

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