We often take freight moving across America for granted. Yet, without dedicated infrastructure along specific corridors — tracks, bridges, and causeways — handled by individual carriers under specific rules, we could not get the goods we need daily. When that system works well, consumers rarely notice. When it breaks down or operates below potential, the costs appear everywhere: in higher prices, longer lead times, and strained supply chains that cannot meet unexpected demand.
This is the context for evaluating the proposed Union Pacific and Norfolk Southern merger — not as a Wall Street transaction or referendum on consolidation, but as a question of whether the freight network truly serves the national interest. The Surface Transportation Board received a revised merger application from Union Pacific and Norfolk Southern on April 30 after finding the original December 2025 filing incomplete. The Board is expected to rule on completeness by the end of May. That process appears to be moving carefully, as it should for a transaction of this scale. The policy conversation should not wait for the lawyers.
The fundamental challenge facing American freight is its organizational structure. It is a system shaped by competing rail barons and the territorial rivalries of a bygone era. Long-haul shipments often cross multiple railroads before reaching their destination. Each interchange point adds time, cost, and uncertainty. Shippers absorb those costs. Retailers do as well. And consumers absorb them too, usually without knowing it. The American Transportation Research Institute calculated that highway congestion alone added more than $108 billion to trucking industry costs in a single year. These costs do not stay on the loading dock. They flow through every layer of the supply chain.
Rail offers a demonstrably more efficient alternative for long-haul freight. Freight railroads move one ton of cargo nearly 500 miles on a single gallon of fuel, three to four times as efficiently as trucks on a comparable basis. That is a significant economic and environmental advantage that the country is only partially realizing, because the existing network was not designed for seamless coast-to-coast service. Trucks remain essential, particularly for first- and last-mile delivery, and a better rail network makes the overall system stronger, not weaker.
Union Pacific has traditionally served the western half of the country, while Norfolk Southern serves eastern ports and industrial centers — which means a combined network would likely reduce inefficiencies, providing shippers with more reliable schedules, fewer handoffs, and better end-to-end visibility. Those improvements translate into real savings that ultimately show up in consumer prices.
This does not mean any merger should close without serious scrutiny. We also need an honest conversation about competition — and the limits of protecting it. Sometimes, in our zeal to preserve market structure, we have blocked combinations that might have kept struggling carriers viable and the network stronger. Like most things in policy, it is a balancing act.
BNSF Railway, which competes with Union Pacific in the West, says the revised application lacks sufficient information for a proper competitive assessment. Other railroads, shippers, and short line operators have questioned market concentration, captive shipper pricing, and competitive access — especially once a combined network controls about half of domestic rail freight volume. These questions deserve well-contemplated answers, not procedural delays.
The STB has the authority and the duty to impose meaningful conditions if it approves the transaction. These include enforceable service quality standards, guaranteed interchange access for short line railroads, pricing transparency, and clear penalties for service failures. These conditions can determine whether a merger delivers on its promise or simply consolidates market power without public benefit.
There is a broader infrastructure picture worth considering. Federal highway funding has dropped in real terms since the early 1990s. Public resources cannot keep up with the maintenance backlog on the national road network. President Trump has even proposed suspending the federal gas tax, which funds roads and bridges, in response to fuel price pressures. Private capital flowing into freight rail infrastructure helps ease that burden — without needing a congressional appropriation and without adding to the federal balance sheet.
The Alliance for Innovation and Infrastructure, which I chair, does not take positions for or against specific mergers. What we consistently advocate, on a non-partisan basis, is that infrastructure decisions be judged on performance, not ideology. Does a proposed change make the system more reliable, efficient, and resilient? Does it serve the public interest over the long term? These are the right questions for any major change to national infrastructure.
The operational need for a more integrated rail network is real. The STB is well-positioned to weigh the competitive risks and arrive at a balanced decision — provided the process moves forward without procedural hurdles that create unnecessary delay. In an industry where timeliness is everything, the review itself should model the standard.
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