Union Pacific is seeking regulatory approval for an $85 billion acquisition of Norfolk Southern to create the first railroad operator spanning the continental United States.
The company said the merger would result in 36% market share based on carloads. That estimate excludes the double-count from interline shipments, the company said.
The Stop the Rail Merger Coalition, which includes six state attorneys general, rival railroads, labor unions and agricultural and chemical industry groups, says creating a railroad with 50% market share of domestic rail freight would reduce competition and boost shipping costs that consumers ultimately pay.
Berkshire Hathaway-owned BNSF said in an STB filing this month that only Union Pacific and Norfolk Southern would benefit from the merger, noting that the resulting company "will have every incentive and opportunity to apply UP’s longstanding high-price strategies on a national scale." BNSF declined to comment.
The U.S. transportation industry applies fuel surcharges using benchmarks such as the Department of Energy's On-Highway Diesel Fuel price and a proprietary formula, known as a "trade factor." Surcharges have withstood legal challenges and regulatory scrutiny over decades.
“Rail fuel surcharges overall are up 43 cents a mile since March and now sit above the previous record from September 2008. That's not a typo,” said Kyle Henzel, president and chief operating officer at shipping platform Ship.com.
There is generally a lag of up to two months between fuel price moves and railroad surcharges. This year's March fuel surcharge, for example, was based on the January diesel price, before the Iran war started.
In the first quarter, as a result, Union Pacific collected $607.6 million in fuel surcharges, $34.8 million less than it paid for fuel, its STB filing showed.
But in the combined first and second quarters, Union Pacific's surcharge revenue was $56.4 million more than its fuel costs.
Union Pacific was the only major railroad to report fuel surcharges that exceeded fuel costs for the first half of 2026.
The biggest gap was between Union Pacific and BNSF, which compete for dominance in the western United States. BNSF's surcharges were $658.1 million less than its fuel costs during the first six months of this year, according to STB filings.
Last year, Union Pacific's total fuel surcharge revenue was $2.3 billion, $48 million less than what it paid for fuel, the company's STB filings showed.
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