Why it matters: Fewer rail options can reduce leverage on pricing, service, and reliability.
This includes:
- 2-to-1 customers: For facilities that today can choose between Union Pacific and Norfolk Southern, they would have only one option after the merger
- 3-to-2 customers: Facilities that today have three rail options, but would drop to two
Pre merger, Shippers Have a Choice of UP or NS.

Pre merger, Shippers Have a Choice of UP, NS and BNSF
The Application names only three 2-to-1 customers but does not include any 3-to-2 customers. CN’s comments on completeness gave additional examples of 2-to-1 locations in downstate Illinois and examples of 3-to-2 locations in Des Moines, Iowa and Danville, Illinois. Other facilities may be similarly situated (See here pg. 43-45 of the PDF for 2-to1 and pg. 46-48 for 3-to-2)
Ask yourself:
Does your facility have access to both Union Pacific and Norfolk Southern?