STB Says It Received Revised Union Pacific–Norfolk Southern Merger Filing; Completeness Comments Due May 8

The Surface Transportation Board, the federal agency that must approve major U.S. railroad mergers, said Thursday that it has received a revised merger application from Union Pacific and Norfolk Southern and set near-term deadlines for the first procedural question: whether the filing is complete.

In a press release dated April 30, the board said comments on the completeness of the revised application are due by Friday, May 8, at noon EDT, and the railroads’ reply is due Tuesday, May 12, at 5 p.m. EDT. “The Board further announced that comments on the completeness of that revised application are due by Friday, May 8, 2026, at noon EDT,” the agency said.

The board made clear it is not yet asking for comments on whether the merger should be approved. For now, the question is narrower: whether the revised filing includes the information required under federal merger rules in 49 C.F.R. part 1180. After that limited comment period, the board will decide whether to accept the application as complete or reject it as incomplete.

If the revised application is accepted, the case would move past that gatekeeping stage and into formal merits review. The board said it would then issue a procedural schedule for the next phase of the proceeding, Docket No. FD 36873, formally titled Union Pacific Corporation and Union Pacific Railroad Company—Control—Norfolk Southern Corporation and Norfolk Southern Railway Company.

Thursday’s filing is the latest step in a process that began with the companies’ notice of intent on July 30, 2025, followed by their initial major merger application on Dec. 19, 2025. The board rejected that first application on Jan. 16, 2026, without prejudice to refiling. In Decision No. 9, the STB said: “The Application is incomplete because it does not contain certain information required by the Board’s regulations.” The board said at the time that the filing lacked, among other things, required forward-looking impact analyses and parts of the full merger documentation.

Union Pacific and Norfolk Southern had told the board in a Feb. 17, 2026, letter that they expected to submit a revised application on April 30, and they did so on schedule. The board previously classified the proposed combination as a “major” transaction under its merger rules because it involves two Class I railroads, the largest category of freight railroad in the United States.

The proposed deal, announced in July 2025 and described in company SEC filings as worth about $85 billion, would combine two of the country’s biggest freight rail operators. The companies have said the merger would create the first U.S. transcontinental railroad under single ownership, making it one of the most consequential rail merger proposals in decades.

For now, however, the immediate issue before the STB is procedural, not substantive. The next milestone in FD 36873 is the board’s completeness review, with comments due May 8 and the applicants’ reply due May 12.