From Trains magazine
In Episode 4 of the TrainsPRO Podcast, Trains Magazine Editor Bill Stephens speaks with Zach Andersen, chief of staff and vice president of communications at BNSF Railway, about BNSF’s fierce opposition to the proposed Union Pacific–Norfolk Southern merger.
Andersen joined BNSF in 2006 as director of federal government affairs and previously served as assistant vice president of public affairs. The conversation centers on what has become the dominant topic in the rail industry since July 2025—Union Pacific and Norfolk Southern’s announcement of plans to merge into the first coast-to-coast railroad in the United States.
Unprecedented Market Concentration and Customer Impact
Andersen frames BNSF’s opposition around a straightforward premise: “It really doesn’t matter what BNSF thinks; it matters what our customers think, and that’s what our customers are telling us.” He argues this consolidation would transform four transcontinental networks into two, causing shippers to lose options and creating captive locations.
According to Andersen, a combined UP/NS would control approximately 50% of all originated rail units in the United States. While UP/NS disputes this figure, claiming 40% of gross ton-miles, Andersen counters that “customers don’t buy GTMs—freight is sold by units.”
Andersen argues this concentration would never survive traditional antitrust scrutiny. “If this were subject to Department of Justice antitrust review instead of the STB, it would be thrown out for exceeding market concentration thresholds,” he says. The STB’s 2001 merger rules, he adds, were explicitly designed to prevent this final round of consolidation.
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Gateway Competition and Economic Closure Risks
A critical concern involves major gateways from Chicago through St. Louis, Memphis, and New Orleans. While UP/NS have promised to keep these gateways open through Committed Gateway Pricing, Andersen points to CPKC’s 2023 acquisition of Kansas City Southern as a cautionary tale.
CPKC promised to keep gateways open on “commercially reasonable terms,” yet BNSF’s interline business at Laredo, Texas dropped from 10,000 loads per month to zero. “Is it economically open? No. That’s why we shifted the traffic over,” Andersen explains.
Andersen notes UP vigorously opposed CPKC’s gateway assurances, only to offer essentially the same mitigation. “What UP said would happen with CPKC is exactly what happened, and now they’re saying, ‘Let us do it too, but we’ll add Committed Gateway Pricing to mitigate it,'” he observes. “That doesn’t seem to be offered in good faith.”
The Committed Gateway Pricing program applies to less than 1% of all rail traffic, excludes intermodal and auto traffic, and is temporary. Customers have proposed reciprocal switching solutions at gateways—measures Andersen calls “likely table stakes” if the merger proceeds.
Trackage Rights Constraints and Open Access Debates
BNSF has filed responsive conditions requesting trackage rights over NS from Chicago to Eastern Pennsylvania for intermodal traffic, along with a neutral switching carrier for Gulf Coast facilities. However, Andersen emphasizes these are fallback positions rather than a path to approval.
“Our position remains that this merger should be rejected by the STB. No basket of concessions is sufficient to mitigate the permanent competitive harm this causes,” Andersen states.
Andersen expresses deep skepticism about trackage rights functioning effectively, pointing to UP CEO Jim Vena’s recent statement: “Why would that work? We’ll just raise the trackage rate.” Andersen says this “exposes the game right there.” Without a self-executing structure preventing economic manipulation, “there isn’t a lot of faith in trackage rights alone.”
On broader open access, Andersen notes that when Hunter Harrison proposed CP’s acquisition of NS years ago, he “put open access on the table as table stakes for a merger of this size, saying competition wasn’t something to be afraid of.”
Highway Conversion Realities vs. Partnership Models
UP/NS have projected shifting 2.1 million truckloads annually to rail—a claim Andersen finds unrealistic. UP’s overall volume has shrunk since its last merger, “moving less volume at higher revenue-per-unit rates than the industry average.”
An Oliver Wyman report found the primary reason over-the-road freight doesn’t shift to rail is that railroads were unresponsive—not interchange time. “If interchange time isn’t driving shipper decisions, why would a merged UP/NS suddenly trigger massive conversions?” Andersen asks.
Intermodal growth is already happening without consolidation. BNSF and CSX expanded interline intermodal offerings last year, achieving truck conversions and share growth in the East. Interchanging an intermodal train typically takes less than an hour—”it’s a step-on, step-off operation.”
Andersen points to BNSF’s Quantum service with J.B. Hunt as proof railroads can win share through responsiveness rather than mergers—the service “has grown every year since launching two years ago and maintains nearly a 100% customer retention rate.”
On carload traffic, Andersen notes an overlooked factor: density. A merged UP/NS won’t run a six-car train from North Platte, Neb., to Buffalo, N.Y.—they’ll wait for a full train load. “Without density, single-line service doesn’t automatically create conversion opportunities.”
Supply Chain Risks and Growing Opposition
Andersen warns that integration-related service problems are historically inevitable, pointing to the UP/SP “total meltdown that reverberated through Texas and the national supply chain.” At UP/NS scale, disruptions “would spread throughout the entire national supply chain.”
Opposition is mounting rapidly. Over 180 members of Congress—both Democrats and Republicans—have expressed concern or called for rejection, compared to just seven in favor, five representing Nebraska. Many individual shippers fear reprisal—”a nail gets hammered”—and are voicing opposition through trade associations representing over 50% of total U.S. rail freight.
Looking ahead, BNSF continues investing in organic growth. The Barstow International Gateway is on track to open in early 2029, while a new Phoenix intermodal terminal will add capacity within months. Andersen describes these facilities as the real path to converting highway freight—”by changing the game, providing a consistent product, creating supply chain resilience, and clearing ports faster.”
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