Rival Class I railroads and a number of short line and regional operations intend to ask the U.S. Surface Transportation Board to grant them trackage rights to various parts of a combined Union Pacific-Norfolk Southern network if the federal regulator approves the proposed merger.

In a flurry of filings in early September, operators from BNSF Railway to the Wheeling & Lake Erie all announced their intentions to participate in the ongoing review of UP’s plan to acquire NS. While the filings did not need to detail how they would participate, many hinted at what they would ask in return for supporting the merger — or at least dropping opposition.

BNSF has been among the most vocal opponents of the merger and said in filings that its opposition will not change. However, if the board were inclined to let UP and NS merge, BNSF planned to ask for trackage rights east of Chicago into Pennsylvania on NS lines. Meanwhile, CPKC officials said they plan to ask the STB to protect its existing trackage rights on UP and NS and to grant new access, particularly between Kansas City and St. Louis. CSX was also planning to ask for rights into the Midwest.

Some of the most interesting proposals, however, came from several short lines. The Wheeling & Lake Erie announced it would ask for trackage rights over NS track to reach the Belt Railway Company of Chicago. The Reading & Northern, on the other hand, was asking for trackage rights south to Hagerstown, Md., in order to connect with CSX. Other short lines that have said they will ask for trackage rights include New Orleans Public Belt, the Columbus & Ohio, Indiana & Ohio, Chicago, Fort Wayne & Eastern, and others.

In August, the STB set a timeline to review the merger, suggesting the earliest it could be approved was sometime in the second half of 2027. If approved, the combined UP-NS would stretch more than 50,000 miles and touch 43 states. The merger was first proposed in mid-2025, but the STB rejected UP’s first application as “incomplete.”

—Justin Franz