Something odd recently showed up in the San Antonio Express News: a column opposing the proposed Union Pacific-Norfolk Southern merger. The piece warns about competitive risks and consolidation concerns. Standard merger opposition stuff, except for one thing: it's entirely about Pennsylvania.
Pennsylvania workers. Pennsylvania steel. Pennsylvania grain. Pennsylvania chemical plants. Nothing about Texas. Nothing about San Antonio. Nothing about how the merger might affect freight operations across the state or port operations in Houston and Corpus Christi.
The author is Bob Comeaux, listed as a contributor. There is a real Bob Comeaux in San Antonio, a former VIA transit board member who writes occasionally about local issues. But his published work doesn't typically focus on federal railroad policy or Pennsylvania agriculture.
That's the first oddity. The broader opposition campaign against the merger contains several more.
The Competitors Line Up
Across the country, opposition to the UP-NS merger is popping up in remarkably coordinated ways. State attorneys general are sending letters. Industry groups are releasing statements on synchronized timelines. Opinion pieces are appearing in newspapers across multiple states using similar arguments.
For Texans, this matters. Union Pacific operates across Texas. The merger would affect freight movement through Houston, Dallas, and across the state. More efficient rail networks could mean lower shipping costs for Texas manufacturers, petrochemical companies, and agricultural shippers. It could also mean more freight stays on rail instead of trucks on Texas highways.
But understanding who benefits from blocking this deal matters more than the merger's hypothetical benefits. And a lot of people benefit from stopping it.
The Stop the Rail Merger Coalition was formally launched in April. Its membership includes the American Farm Bureau, American Chemistry Council, Teamsters Rail Conference, BNSF Railway and others. Some of these organizations have genuine reasons to worry about rail consolidation. The Farm Bureau has worried for years about what rail mergers do to agricultural shippers. The Chemistry Council tracks how consolidation affects manufacturers.
But here's the thing: BNSF and CPKC, the two railroads positioned to lose the most if UP and NS combine, are also driving this opposition.
BNSF would face its first serious transcontinental competitor. That's bad for BNSF's bottom line. BNSF also operates heavily in Texas. CPKC, the Canadian company created in 2023 when Canadian Pacific bought Kansas City Southern, has a different problem. CEO Keith Creel has been explicit about CPKC's strategy: position the railroad as a "land bridge" that avoids U.S. infrastructure.
"We’re the land bridge that makes it possible (Trains).” Creel continued to analysts “And that’s unique to our railroad. No other railroad can do that.”
"Our value proposition is that we can move traffic through Mexico and Canada without routing through the United States."
A unified UP-NS network offering single-line coast-to-coast service destroys that strategy. Both competitors have massive financial incentives to see this merger blocked.
The Montana Connection
Montana's Attorney General Austin Knudsen led the opposition letter from state attorneys general. That single detail is worth examining closely.
Montana is where BNSF almost exclusively operates. Not partially. Almost exclusively. BNSF's western network, its transcontinental routes, its major freight corridors, its rail yards. They're all centered on Montana. The railroad is essentially Montana's freight backbone.
Knudsen's office submitted a letter opposing the merger and didn't mention that the state's dominant freight railroad stands to lose significant market share if UP and NS combine. The letter framed concerns in the neutral language of public interest. But separating Montana's opposition from BNSF's competitive interests isn't easy to do.
The same issue appears relevant for other state attorneys general who signed on. North Dakota, South Dakota, and Kansas all have significant BNSF operations. All states where BNSF has major presence and influence. That's not a coincidence.
This doesn't automatically mean the concerns are illegitimate. BNSF operates in these states and employs thousands of people there. When BNSF's interests shift, the states' interests often shift with them. Rail workers live in these states. Rail customers operate there. There are real alignment points.
But it's reasonable to ask whether these state positions reflect independent regulatory analysis or reflect the preferences of the railroads operating heavily in those states. When the attorney general of Montana, where BNSF essentially operates as the dominant freight carrier, leads opposition to a deal that would create BNSF's first serious competitor, that warrants some scrutiny.
The Labor Twist
Here's where it gets more complicated. The nation's largest railroad union, SMART-TD, endorsed the merger after Union Pacific guaranteed lifetime job protection for every union member and committed to 1,200 new union jobs within three years.
But the Teamsters Rail Conference, which is part of the opposition coalition, continued raising concerns about worker impacts despite the labor agreement.
The disconnect points to something worth understanding. The Teamsters' largest membership isn't rail workers. It's truck drivers. A more efficient transcontinental railroad that reduces interchange delays and speeds freight movement could shift shipments from trucks to rail. That's good for rail workers but potentially bad for trucking employment.
The Teamsters' opposition to the merger may be driven less by railroad labor concerns and more by the threat to trucking jobs. That doesn't invalidate their position, but it's important context for understanding who the opposition coalition actually represents.
The Pattern
Here's what's visible: A Canadian railroad company positioning itself as a bypass to U.S. infrastructure. A domestic competitor that would lose market share. Attorneys general from states where those competitors dominate. Industry groups with legitimate concerns being amplified through coalition messaging. A labor union whose opposition may reflect trucking interests more than rail worker concerns.
All coordinated under a single coalition. All making public-interest arguments. All appearing in state newspapers around the same time.
The Pennsylvania column in the San Antonio Express News fits this pattern. It's the type of thing you'd produce to create an impression of grassroots opposition without explicitly acknowledging central coordination – astroturfing.
For Texas specifically, there's another angle worth considering. If CPKC succeeds in using this campaign to kill the UP-NS merger, then a Canadian railroad has blocked American infrastructure development using American advocacy groups as proxies. That's a Canadian company avoiding U.S. infrastructure while using U.S. institutions to prevent competitors from building better U.S. infrastructure.
Texas policymakers might want to think about whether that serves Texas interests.
The Surface Transportation Board will conduct a detailed review of the merger. That scrutiny is appropriate. But the opposition campaign itself is worth examining, too. Understanding who benefits from the outcome and whether competitor interests are masked as public interest claims matters for how American infrastructure decisions get made, especially for states like Texas that depend on efficient transportation networks.
