What's Happening
Union Pacific (UP) and Norfolk Southern (NS) have filed a revised merger application with the Surface Transportation Board (STB) seeking approval to combine into a single transcontinental railroad.
The STB is the federal agency charged with reviewing and deciding whether this merger should be approved. As part of its process, the STB considers input from customers and other stakeholders when evaluating whether a proposed transaction satisfies its rigorous regulatory standards. While industry associations and similar collective groups can be strong advocates, your voice as an individual shipper provides unique insight that is critical to the STB’s analysis.
CSX wants to be of service as shippers assess how the proposed merger between UP and NS would impact their business. We also want to ensure that our customers understand how their participation in the merger review process can help preserve fair competition in the rail industry.
What CSX Believes
CSX has carefully reviewed the revised application to assess what the proposed transaction could mean for shippers across the country and the long-term health of the rail network. Based on this review, CSX believes the proposed transaction would create an industry imbalance that would reduce viable options for shippers.
Today’s Class I rail industry is competitively balanced, with two western railroads, two eastern railroads, and two Canadian railroads. The proposed transaction would replace that balance with a single transcontinental railroad competing against several regionally focused carriers – an outcome that would significantly narrow the competitive options available to shippers.
For our customers, this would mean fewer viable routing options and a rail system less equipped to serve the supply chain of the U.S. economy for years to come.
CSX will be formally expressing these concerns to the STB, and we encourage our customers and other affected stakeholders to do the same.
Stay Engaged, Stay Informed
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The STB’s review of the UP/NS merger may be the most consequential regulatory proceeding in the history of American freight rail. The decisions made here will shape the competitive landscape for decades.
The STB gives significant weight to the views of individual shippers when evaluating whether a merger is consistent with the public interest. We encourage you to participate in the STB process and make clear to regulators how this merger will directly affect your operations and business. Your voice matters, and now is the time to use it.
CSX will continue to share updates as the process develops. Stay engaged and check back here for guidance throughout the STB review.
– Steve Angel, CEO, CSX
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While we will issue our response after our thorough analysis of the application, CSX will continue to focus on our core priorities:
- Keeping our employees and communities safe.
- Delivering reliable rail service to all our customers.
- Unlocking value for shareholders.
- Investing in the best team in the rail industry.
Why You Should Care
The STB is required to assess whether this merger serves the public interest and enhances competition. That determination will be shaped significantly by what shippers, businesses, and stakeholders tell them.
Regardless of how you choose to participate, consider the following questions as you review the merger application:
- Would this merger help or hurt rail customers in your industry?
- How would a merged UP/NS impact your shipping options?
- What is your confidence in the ability of the proposed merger conditions to protect your business, and will they remain accessible and enforceable over time?
Many shippers have raised questions about whether merger conditions alone would be sufficient to address the risks associated with a transaction of this scale.
The STB Provides a Forum that is Open to All Stakeholders
The STB welcomes all stakeholders — including rail customers, warehouse operators, terminal operators, unions, and the general public — to share their views on these types of issues, including potential concerns about rail competition and service. The STB takes such feedback into account before making a decision.
We have received inquiries from our customers on how they can be more involved in this process and have their voices heard.
Make Your Voice Heard
The STB gives significant weight to the views of individual shippers and customers when evaluating whether a merger is consistent with the public interest. There are three primary ways to make your voice heard:
FILE WITH THE STB
File a Notice of Intent to Participate (NOI) with the STB no later than June 12, 2026. This allows you to formally participate in the proceeding and receive copies of all filings on the docket, without requiring you to take any formal position. You may also submit a signed letter or formal comments describing your specific concerns.
File at: stb.gov/proceedings-actions/e-filing/formal-filings/ — Docket No. FD 36873
Note: Pleadings must be served on all parties of record; service can be made by email.
SPEAK WITH THE DOJ
The Transportation, Energy, and Agriculture Section of the U.S. Department of Justice Antitrust Division also wants to hear your concerns. Communications with DOJ are confidential under their confidentiality policy.
Contact: [email protected]
CONTACT THE STB'S RAIL CUSTOMER PUBLIC ASSISTANCE PROGRAM
The STB’s Rail Customer Public Assistance (RCPA) program is available to help rail customers with the regulatory process. The RCPA can be reached at 1-866-254-1792 (toll-free) or 202-245-0238.
Contact: [email protected] | Form
Notice of Intent Filing Deadline
Advocacy to Consider
If you choose to file comments or a letter with the STB, firsthand accounts describing how the proposed transaction could affect your business can provide important context for regulators. Consider addressing the following:
The stakes for the U.S. economy. A competitive rail network is essential to American economic strength and global competitiveness. Consolidation that weakens competition puts both at risk.
The value of the current competitive landscape. The east-west competitive balance in the rail industry today gives shippers real choices. It allows you to mix and match among the four major U.S. railroads to create as many as four different competitive choices for pricing and routing. Describe what those choices mean for your business, how you use them to get competitive rail service, and what losing them would cost.
The importance of interline rail service to your operations. Provide specific examples of lanes or shipments where interline options have delivered important pricing, service, or reliability, and explain what foreclosing those options would mean for your supply chain.
The necessity of continued rail infrastructure investment. Fair competition enables carriers to invest in their networks. Share specific examples of infrastructure improvements that have benefited your operations, and explain what is at risk if post-merger consolidation creates an imbalance that erodes the ability of non-merging railroads to invest.
The impact of rail service disruptions on your business and your customers, e.g., when supplies cannot get to your production facilities or your products cannot get to your customers on time.
What Comes Next
Frequently Asked Questions
A Notice of Intent to Participate (NOI) is a brief submission to the Surface Transportation Board (STB) that provides public notice that you, your company, or your trade association may participate in the merger review proceeding before the STB. Filing an NOI preserves your ability to be heard as the STB evaluates the proposed Union Pacific (UP) and Norfolk Southern (NS) merger.
Any customer, shipper, trade association, or other stakeholder who may want to formally comment on the merger’s competitive impacts — or ask the STB to impose conditions if it approves the transaction — must first file an NOI. It is the gateway to full participation in the proceedings.
You will need to file your NOI directly with the STB using docket number FD 36873. There are two formats available — a less formal letter addressed to the Chief of Case Administration, or a more formal submission with a full case caption. Either version is acceptable. Both formats require confirmation that all parties of record have been served by email. Once filed, the email address associated with your NOI will receive all merger-related correspondence going forward. CSX is pleased to assist — contact us for detailed guidance on the process or help accessing the necessary resources.
The NOI deadline is typically set at 45 days after the merger application is filed. UP and NS refiled their application on April 30, 2026, which suggests an expected deadline of approximately June 12, 2026. The STB will confirm the official schedule. We encourage you to file as soon as possible — doing so now guarantees your ability to participate regardless of how the schedule evolves.
Filing an NOI does not obligate you to take any further action. You will have the option to submit written comments, request conditions, or participate in any public hearing the STB schedules — but none of those steps are required simply by filing. You will also begin receiving electronic copies of all filings submitted in the proceeding, which will help you stay informed as the review progresses.
No. There is no filing fee for a Notice of Intent to Participate.
From the STB’s main page, click on “E-filings” and then “Formal Filings.” Before submitting, email a copy of your NOI to all parties of record on the service list. On the Formal Filings page, check the box confirming you have complied with the service requirement and click “Continue.” Enter the docket number — select “FD” for Finance Docket (it defaults to “AB”) and enter 36873 in the field to the right. Select “No Fee Required” for the filing fee. Enter your party information using your business address; if you have legal representation, your attorney may file on your behalf. Upload your NOI, check “Public,” confirm you understand the filing will be publicly available, and click “Submit Formal Filing.” You will receive a confirmation email from the STB. If you need assistance at any point, contact CSX or the STB’s RCPA office for additional support.
You are required to email your NOI to all current “parties of record” — meaning everyone who has already filed a notice in the proceeding. The service list with current email addresses is available through the STB’s website. Because assembling the list can be cumbersome, contact CSX when you are ready to file, and we will provide you with the most current email roster, which you can paste directly into the filing form.
Yes — and the sooner the better. Filing an NOI does not commit you to any position or further action. It simply preserves your ability to engage if and when you decide to. UP and NS are required to demonstrate that their merger enhances competition and serves the public interest. Assessing the full impact of the merger on your business may take time, and filing now ensures you have every option available to you as the proceeding unfolds.
Contact the STB’s Office of Section Case Administration at 202-245-0350. If your filing was posted to the STB’s website but you did not receive a confirmation, it may indicate a question about whether all parties of record were properly served — the same office can help resolve that as well.
As of May 15, 2026, the STB has received notices of intent to participate from over 150 entities. Voices from around the country are being heard — yours can too. View the full list here.
Stay In Touch
The window to act is short. If you have questions about the process, would like assistance with a filing, or prefer to share your concerns confidentially, please reach out. We are glad to work with you to ensure your voice is heard.
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