The Surface Transportation Board (STB) “should reject the efforts of a few parties … to delay and prolong this proceeding by claiming the [recently filed Union Pacific-Norfolk Southern] Application [seeking authorization to combine their networks under common ownership and form a U.S. transcontinental] is incomplete,” the two railroads urged in a Jan. 2 filing. The approximately 6,700-page control application, including verified statements from 19 company witnesses and independent experts, along with more than 142 gigabytes of supporting workpapers, “demonstrates that the proposed transaction presents an unprecedented opportunity to drive growth, enhance competition, and create a more accessible, sustainable, and lower cost supply chain option that will benefit American businesses and consumers,” UP and NS wrote. “The Application contains all the information required by the Board’s merger rules, 49 C.F.R. part 1180, and presents a prima facie case that the proposed transaction is consistent with the public interest. The Board therefore should accept the Application.” According to UP and NS, the parties claiming that the application is incomplete are “primarily competitors,” who will “experience increased competition as a result of the merger.” They include BNSF, CN, Canadian Pacific Kansas City, and CSX, plus the National Grain and Feed Association (NGFA), representing one of the railroads’ largest customer bases. UP and NS noted that the STB “should also disregard the improper efforts of these same parties to litigate the merits of the Application at this time, directly contradicting the Board’s explicit instructions to the contrary. See Decision No. 7 at 1 (‘[C]omments…
