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Submit a Comment: Oppose the UP–NS Merger

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We understand that some railroaders may need or want to submit their comment confidentially and with anonymity during the public comments process to the STB. Trust in government agencies has been shattered. While the STB website offers a contact within the Department of Justice to receive anonymous comments, we cannot assume names would remain confidential. 


As a Party of Record, Public Rail Now will submit comments on behalf of railroaders that wish to remain anonymous. Please submit your comment, questions or concerns to info@publicrailnow.org. 

Step 1: Select your reason for submitting a comment and draft a comment using the suggested prompts below.

With the advancement of AI being used to comb through comments, we suggest using the comment prompts below as a starting point to draft a more personalized comment about how this merger will impact you and your community. The most useful comments are specific, not general statements of support or opposition. Where possible, include: (1) the specific rail line, corridor, or facility affected; (2) how you or your community interact with it today (shipping volume, commute, proximity to tracks, emergency access); (3) what you expect to change and why; (4) any direct experience with service quality, delays, or safety issues. Please write in your own words — comments that closely mirror each other carry less weight with the Board.

Railroader: People who operate, maintain, dispatch, and service the rail network and understand its realities from the inside.

Prompt: You oppose the proposed merger because my frontline rail experience shows that reduced staffing, extreme cost-cutting, and longer trains increase safety risks. Rail unions representing tens of thousands of railroad workers — including the Brotherhood of Locomotive Engineers and Trainmen and the Brotherhood of Maintenance of Way Employees — oppose this deal, citing safety, labor, and cost concerns. They point out that promises to protect jobs lack detailed guarantees, and that past consolidations left workforce safety and community risk behind corporate cost-cutting agendas.

Farmers & Agricultural Producers: Depend on affordable, reliable rail service to move crops, fertilizer, livestock feed, and equipment. Rail competition directly affects farm income and rural economies.

Prompt: You oppose the proposed Union Pacific–Norfolk Southern merger. Add personal experience and details of how this merger will impact you, such as: Agriculture depends on competitive, reliable rail service to move grain, fertilizer, livestock feed, and equipment. Rail consolidation has already reduced competition in the freight rail market, leaving shippers with fewer options and higher rates. U.S. railroads have consolidated from more than 100 Class I carriers in the 1950s to just six today, and farmers are paying more for service that often falls short of needs. Shippers groups warn this merger will increase costs and degrade service for bulk commodities like grain and fertilizer, harming farms and rural economies.

Trackside Community Members: Residents who live, work, or attend school near rail lines and are directly affected by safety risks, noise, pollution, and emergency response delays.


Prompt: You oppose this merger as someone who lives near the railroad. Add personal experience and details of how this merger will impact you, such as: Rail accidents and toxic derailments — including the high-profile incident in East Palestine, Ohio — show that when safety margins are tight and staffing levels are minimized, the consequences for communities can be catastrophic. Major freight carriers, including Norfolk Southern, have not fully participated in proven safety programs designed to prevent incidents like this, even years after the derailment, raising real concerns about expanded networks with even fewer local safeguards. 

Rail passenger: People who rely on passenger rail for commuting, travel, and access to jobs and services. Freight railroad decisions directly affect passenger safety and reliability because they share the same tracks.

Prompt: You oppose the UP–NS merger as a rail passenger. Add personal experience and details of how this merger will impact you, such as: Past railroad consolidation has led to staffing cuts, deferred maintenance, and network congestion, increasing delays and raising safety concerns for passenger service. There is also a real risk that a larger consolidated railroad will abandon routes and track segments, eliminating existing and future passenger rail service. Giving even more control of critical rail corridors to a single company would make it harder to improve reliability, expand service, and preserve the rail connections the public depends on.

Logistics & Transportation Workers: Workers in ports, warehouses, trucking, and intermodal operations whose jobs depend on a stable, functioning rail system.

Prompt: You oppose the UP–NS merger because it threatens logistics jobs and overall freight system performance. Add personal experience and details of how this merger will impact you, such as: Rail labor leaders have warned that without meaningful worker input, a mega-merger could cause “meltdowns” in freight operations, increasing congestion, disrupting supply chains, and putting pressure on logistics workers on land and at intermodal hubs. Having too much freight controlled by a single carrier limits flexibility in supply networks and puts additional strain on workers already coping with service breakdowns and workforce reductions. 

Shippers & Small Businesses: Manufacturers, distributors, and exporters who rely on rail to reach customers and compete in the marketplace.

Prompt: Adding personal experience and details of how this merger will impact you because it will further concentrate market power among too few rail carriers, reducing competition and raising costs for businesses that ship by rail. Groups representing chemical, manufacturing, agriculture, and energy companies warn that reduced competition will lead to higher shipping rates and worsening service, especially for industries that rely on unit trains and long-distance freight. In addition, past mergers have shown that enforcement of competition conditions is difficult and often ineffective, leading to delays and lost service options for shippers.

General Public: Community members, consumers, and taxpayers who rely on rail for a healthy economy, safe transportation, and stable supply chains.

Prompt: Adding personal experience and details of how this merger will impact you, such as rail competition, safety, and service reliability are critical to the national economy and public safety. Safety data show that hundreds of thousands of rail accidents occur in the U.S. each decade, and many safety recommendations go unimplemented. Meanwhile, shippers and policymakers worry that further consolidation will increase transportation costs, reduce service quality, and diminish competition for consumers and businesses. This merger is not in the public interest.

Step 2: Submit your comment to the STB on or before November 18, 2026. 

If you prefer to file an individual comment to the STB: Individuals may file independently, but STB rules require serving a physical or emailed copy of your filing on every party on the case’s service list — which currently exceeds 750 parties and continues to grow — in addition to e-filing with the Board. This is a substantial undertaking not designed for individual commenters.

If you want your voice in the record without taking on that burden, use the form below.

Additionally, PRN is collecting environmental comments now and will file them with the Office of Environmental Analysis (OEA) prior to the deadline. If this sounds confusing, it is because the STB is operating by new rules that have yet to be published and the Environmental Analysis will accept comments separate of the more formal STB e-filing process with a deadline of November 18, 2026.  Environmental hearing dates and the OEA comment period deadline have not yet been announced. info@publicrailnow.org

Step 3: Help us spread the word!

Thank you for taking the time to submit a comment to the STB. Help us solidify the opposition to this merger and the rail barons behind it. Share the link https://form.jotform.com/262374511249053. Let the STB know that this kind of mega-merger is not in our best interest!