Section: Before the Filing
Who signed what, before anyone could read the application
Months before UP and NS filed a single page with regulators, letters about the merger were already circulating in Houston. They fall into two very different groups.
Group 1: The support letters UP collected
When the railroads filed their application on December 19, 2025, it arrived with roughly 2,000 letters of support from elected officials, businesses, and civic groups nationwide. Bloomberg reviewed them and reported that the endorsements traced back to a handful of template letters. Organizations in Washington State echoed the same claims, word for word, as organizations in Texas.
Bloomberg, "Union Pacific Deploys Politicians, No Concessions in Merger Bid," Dec. 29, 2025 (Zach Williams); UP-NS application support letters, STB Docket FD 36873.Here is the timing problem. A public relations firm working for Union Pacific circulated the template before the application existed. Signers endorsed a 7,000-page transaction they could not have read, because it had not been filed. The letters promised local economic growth and reduced highway congestion. The application, once filed, projected hundreds of additional daily trucks at Houston's Settegast Yard and acknowledged the added rail traffic may cause more blocked crossings.
Bloomberg, Dec. 29, 2025; STB filings EI-34157 (Settegast trucks) & EI-34160 (blocked-crossing acknowledgment); "What UP Says vs. What UP Filed," Not Another Houston.What did the template letters promise?
Form letters attributed to local, state, and federal officials described the merger as a win for the local economy, the environment, and millions of Texans, citing job creation and reduced highway congestion. Compare that to the filings on the Discrepancies page. The application itself projects more trucks at Houston's intermodal yard and flags the risk of additional blocked crossings.
UP-affiliated form letter language as documented in "What UP Says vs. What UP Filed"; STB filings EI-34157, EI-34160.What happened to the $750 million in concessions?
Bloomberg reported that the railroads quietly withdrew $750 million in previously touted concessions around the time they filed. UP's later public materials cite $300 million in community benefits. Community advocates note those items map to projects UP had already planned before the merger.
Bloomberg, Dec. 29, 2025; community briefing records, Mar. 2026.A year later: withdrawn, disavowed, affiliated
UP still counts letters gathered in late 2025, before its operating plan and traffic forecasts existed. The docket now shows what happens when signers take a second look.
A Houston shipper read the application and withdrew to neutral
USD Group, a Houston logistics company, sent a support letter in September 2025. In February 2026 it told the Board that after reviewing the December filing it "does not, by this submission, take a position for or against" the merger. The retraction first went to the Board on December 29 and had to be resubmitted five weeks later to reach the public docket.
USD Group LLC letter, STB filing 310831 (entered Feb. 4, 2026), Docket FD 36873.A Harris County Commissioner says his name was used without permission
A support letter from Trees for Houston listed Commissioner Rodney Ellis among its advisors. Ellis told the Board that "neither I nor my office reviewed, authorized, or approved that letter," and stated he stands with Settegast and Greater Fifth Ward residents on emissions and accountability.
Commissioner Rodney Ellis letter, STB filing 310966 (entered Mar. 10, 2026).An Ohio Senate leader formally withdrew his support
Ohio Senate Majority Whip George Lang withdrew his October 2025 support letter in August 2026, citing effects on Ohio farm, chemical, and manufacturing shippers and on railroad jobs. BNSF's September filing notes that other signers of UP's form letters are retracting as well.
Sen. George F. Lang letter, STB filing 312103 (entered Aug. 27, 2026); BNSF-53, STB filing 312262 (Sept. 9, 2026).A Houston support letter came from a group with a UP officer on its board
The North Houston Association's September 2025 support letter appears in Volume 3 of the application. The letter's own masthead lists a Union Pacific public affairs director on the association's board of directors. The application does not flag that relationship. In September 2026 the association's president wrote a Houston Business Journal op-ed backing the merger, also without mentioning it. The same op-ed agreed that residents "deserve input on noise, health and safety concerns" and that regulators should conduct "extensive environmental and traffic studies."
North Houston Association letter, Sept. 25, 2025, UP-NS Application Vol. 3 at 1874; M. Briggs, Houston Business Journal, Sept. 15, 2026; NHA Board of Directors page.Why this matters. The STB weighs public support when it judges the public interest. Support gathered before the application was public tells the Board nothing about whether the actual transaction, with its actual Houston impacts, deserves that support.
Group 2: What Houston officials asked the Board for
Separately, between October and November 2025, Houston-area officials filed formal comments on the docket. Most did not endorse or oppose the deal. They asked for process: a hearing in Houston, honest local data, and time to review. Click each name to see the ask.
Council Member Mario Castillo (District H), Oct. 1, 2025
The first Houston elected official to file. He asked for at least one public hearing in Houston at hours working families can attend, noting the Board held its CP-KCS hearing in Beaumont on a weekday. He requested comprehensive Houston-specific impact analysis and meaningful weight for local government input.
STB filing 310428, Docket FD 36873.Council Member Julian Ramirez (At-Large), Oct. 7, 2025
Requested a Houston hearing in evening or weekend hours, plus transparent city-specific projections: freight volumes, train frequency and length, crossing blockage duration, and emergency response impacts.
STB filing 310413, Docket FD 36873.Harris County Commissioner Adrian Garcia (Precinct 2), Oct. 10, 2025
Cited 8 of the nation's 10 most-blocked crossings in the East End, first responders losing up to 10 minutes at crossings, and an estimated $2.6 billion in delay, collision, fuel, and emissions costs over 20 years. He asked for a Houston hearing, honest localized forecasts, and a full system impact study covering secondary lines and the cascade effects at Houston's at-grade interchanges.
STB filing 310429, Docket FD 36873.Mayor John Whitmire, City of Houston, Oct. 13, 2025
The City's letter names the East End, Greater Fifth Ward, OST/South Union, and Northside as among the most rail-impacted urban areas in the nation, and notes the Houston Fire Department documents hundreds of incidents each year where stopped trains delay or reroute emergency vehicles. The City endorsed the East End Super Neighborhood Coalition's requests and asked for binding conditions on any approval: grade separation funding, limits on train length and idling in residential areas, quiet zones, and noise and vibration protections.
City of Houston comment, Oct. 13, 2025, Docket FD 36873.State Senator Carol Alvarado (SD-6), Oct. 16, 2025
Her letter struck a more supportive tone than the others. It describes the merger as a potential driver of economic growth through the Port of Houston, encourages the companies to keep working with East End residents, and urges the Board to keep safety and quality of life top priorities. It requests no specific hearing, study, or condition.
STB filing 310158, Docket FD 36873.Harris County Attorney Christian Menefee, Nov. 20, 2025
Asked for a rigorous, transparent review, at least one hearing in Harris County, and a comment process with enough time for real analysis. His letter states residents should not have to tolerate service breakdowns, safety lapses, or higher prices because of the deal.
STB filing 310323, Docket FD 36873.Read the two groups side by side and a pattern emerges. The letters UP gathered promise benefits and ask for nothing. The letters Houston officials wrote ask for evidence, access, and protection. Only one of those groups had seen data when they signed.