Key facts
- The National Grain and Feed Association (NGFA) opposes the proposed merger between Union Pacific and Norfolk Southern.
- NGFA has formally requested the Surface Transportation Board (STB) reject the merger.
- The association argues the merger does not meet the STB's 2001 standards for increasing competition.
- NGFA's Board of Directors voted to oppose the merger after reviewing the application and member feedback.
- Approximately 3.2 million rail cars of agricultural products move by rail annually.
The National Grain and Feed Association (NGFA) has formally requested that the Surface Transportation Board (STB) reject the proposed merger between Union Pacific and Norfolk Southern Corporation. In a filing dated August 13, 2026, NGFA stated that the applicants' updated proposal, submitted on July 27, 2026, does not meet the standards set forth in the STB's 2001 Major Rail Consolidation Procedures.
These procedures stipulate that railroad mergers should not only preserve existing competition but actively increase and improve it for customers. NGFA's Board of Directors voted to oppose the merger after a year-long review, concluding that the application does not meet the required standards. The association emphasized that any agreement must deliver tangible benefits for rail customers and the agricultural supply chain.
Agriculture is a sector heavily reliant on rail transportation, with approximately 3.2 million rail cars of grains, oilseeds, and other agricultural products moving by rail annually, representing over 10% of all rail shipments. NGFA has consistently sought greater detail from the merger applicants on how the transaction would enhance competition and serve the public interest.
The applicants have argued that the merger is largely an "end-to-end" combination, with Union Pacific operating primarily in the western United States and Norfolk Southern in the eastern states, minimizing direct route overlaps. However, NGFA maintains that the STB's 2001 rules require more than just preserving competition; they demand enhancement, citing tools like reciprocal switching and trackage rights as potential competitive improvements.