CN Submits Comments to STB on Completeness of UP-NS Amended Merger Application

Executive Summary of Most Recent Release

• Date: May 11, 2026
• Event: Regulatory Update / Legal Filing with Surface Transportation Board (STB)
• Action: CN submitted formal comments urging rejection of the amended merger application by Union Pacific (UP) and Norfolk Southern (NS).
• Core Argument: The amended application remains incomplete, failing to address two of three primary deficiencies identified by the STB in January 2026.
• Specific Deficiencies Cited: Lack of complete competition analysis, inconsistent market share data, inaccurate identification of rail service points transitioning from multiple options to fewer, and missing analyses on downstream competitive impacts.
• Critique of Remedies: CN argues the proposed "Committed Gateway Pricing" (CGP) program is insufficient as it applies to less than 1% of U.S. rail traffic and excludes major categories like finished vehicles and intermodal shipments.

Impact on Company Fundamentals

• Revenue/Cost: No immediate material impact on revenue or operating costs from this filing alone. The merger is a competitor issue, not an operational one for CN.
• Strategic Position: Blocking the UP-NS consolidation maintains the current competitive landscape in North American rail transport. If approved, it could increase pricing pressure on CN's U.S. network due to reduced competition.
• Market Expectations: This filing is consistent with CN's stated strategy over the last 6 months. The market has likely priced in this regulatory opposition as a standard part of the merger review process.

Business Description

• Core Business: Canadian National Railway operates a nearly 20,000-mile rail network transporting over 300 million tons of goods annually across North America.
• Flagship Segment: Grain & Fertilizers movement is a key performance indicator, with recent records set in early 2026 (April: 3.2M tonnes).
• Network Scope: Connects Western Canada to U.S. East Coast and Gulf ports, serving as a critical link for agricultural exports and intermodal freight.