What UP Says vs. What UP Filed
Union Pacific has a carefully managed public narrative about this merger — one built around efficiency, economic growth, and community benefit. But the actual merger filing submitted to the Surface Transportation Board tells a different story.
Filings with federal regulators require specificity. Projections, operational plans, and financial justifications have to be documented. And when you read what UP actually committed to on paper versus what it has said publicly, the gaps are significant.
Communities were told this merger would relieve congestion in congested corridors and reduce delays. The filing reflects a primary focus on shareholder value and network consolidation — with community impact treated as a compliance checkbox rather than a core commitment.
This matters because the public narrative is designed to neutralize opposition. If residents and elected officials are evaluating a merger based on press releases instead of the actual application, they’re not evaluating the same thing regulators are. We read the filing so you don’t have to — and what’s in it deserves a much wider audience.
Claim 1: “Union Pacific’s average train length is 7,500 feet.”
At a Texas House Transportation Committee hearing on April 3, 2025, Union Pacific’s own Senior Director of Public Affairs told lawmakers that UP’s average train length is 7,500 feet.
Their SEC filings tell a different story.
| Quarter | Average Train Length |
|---|---|
| Q1 2025 | 9,490 ft |
| Q2 2025 | 9,689 ft |
| Q3 2025 | 9,801 ft |
| Q4 2025 | 9,729 ft |
Source: UP quarterly earnings reports, SEC filings
Every single quarter of 2025, Union Pacific’s own federally required disclosures show trains running between 2,000 and 2,300 feet longer than what their representative told the Texas legislature. That’s not a rounding error. That’s nearly half a mile of difference.
Why it matters: Every additional foot of train length is additional seconds — sometimes minutes — that an intersection is blocked. For communities in the East End and Fifth Ward, which already experience some of the longest and most frequent blockages in Houston, this gap between what UP says publicly and what it reports to federal regulators isn’t a technicality. It’s the difference between a crossing that’s manageable and one that cuts off emergency response.
When a company tells regulators one thing and legislators another, the question isn’t just accuracy — it’s accountability.
Claim 2: The merger will deliver local economic growth, job creation, and reduced highway congestion as more freight moves by rail— “a win for our city’s economy, our environment, and millions of Texans.”
Elected officials across Houston — local, state, and federal — signed letters declaring this merger would be “a win for our city’s economy, our environment, and millions of Texans.” Those letters, generated through a UP-affiliated PR firm, promised economic growth, job creation, and reduced highway congestion as freight shifts from roads to rail.
Then there’s what UP actually filed with federal regulators.
| Trucks Per Day | |
|---|---|
| Settegast Yard Today | 246 |
| Settegast Yard — Year 5 Post-Merger | 762 |
| Net Increase | +516 trucks every day |
Source: Merger Filing EI-34157, p. 18
That’s a 209.8% increase in daily truck traffic at a single East Houston facility. And it’s not a minor outlier — among thousands of intermodal facilities across the country, Settegast would rank fifth highest for projected truck traffic increase nationwide.
Why it matters: The officials who signed those letters were promised congestion relief. The filing projects the opposite — concentrated growth in truck traffic in East Houston neighborhoods already overburdened by industrial activity, freight corridors, and diesel emissions.
The form letter went to lawmakers. The truck projections went to regulators. The community gets to live with the consequences of both.
But “We Don’t Know Where the Trucks Will Go”
Some have suggested that a 209% increase in truck traffic at Settegast doesn’t necessarily mean more trucks in surrounding neighborhoods. Technically, that’s true. We can’t assign a route to every truck.
But here’s what we do know: Settegast Yard is in East Houston. The streets surrounding it are already strained by freight truck traffic that cuts through residential corridors. And a facility projecting 516 additional trucks per day doesn’t operate in a vacuum — those trucks have to come from somewhere and go somewhere, and the surrounding street network is how they get there.
The question was never whether every single truck would turn left onto a neighborhood street. The question is whether a community that already bears a disproportionate share of the freight burden should be asked to absorb even more — and have that dismissed as speculative.
“We don’t know for certain” is not the same as “it won’t happen.” And for a community with our track record of being on the receiving end of exactly these kinds of impacts, the burden of proof should not be on us.
Claim 3: The merger improves safety, reduces emissions, and eases congestion by shifting freight from trucks to rail.
Union Pacific and Norfolk Southern have made environmental improvement a centerpiece of their merger pitch. Shifting 2 million truckloads to rail, they argue, means cleaner air, less congestion, and a smaller carbon footprint. It sounds straightforward — until you read how it actually works.
The merger’s emissions benefits depend on the availability of seven-day premium intermodal lanes routed through major metro areas. Freight moves by rail — then gets transferred back to trucks at urban terminals like Settegast Yard in East Houston (see Claim 2). The macro headline is green. The local reality is diesel.
A third-party rail industry consultant hired as part of the merger proceedings said it plainly:
“While this is a ‘green’ alternative on a macro scale, it creates severe localized environmental impacts. Consolidating millions of truck movements into a handful of urban intermodal terminals will create localized congestion and air quality ‘hot spots.’”
Source: Merger Filing EI-310718, p. 4 — Atlantic Systems Inc.
The same consultant flagged something else: because truck traffic is technically operated by intermodal carrier partners — not UP or NS directly — those impacts were excluded entirely from the merger’s Environmental Impact Statement.
The pollution didn’t disappear. It was reassigned — to neighborhoods like ours — and then left out of the paperwork.
Why it matters: Environmental justice isn’t just about what gets counted. It’s about what gets left out. When benefits are claimed at the national level and costs are absorbed at the neighborhood level — and then omitted from formal review — that’s not a green merger. That’s a green press release.
Claim 4: The merger includes $2.1 billion in capital investments to support projected traffic growth.
A Multibillion-Dollar Merger. Houston Gets Parking.
Union Pacific has promoted this merger as a massive infrastructure investment. So what does Houston actually get?
According to the merger application itself (STB Docket FD 36873, Vol. II, p. 188 and p. 791), the investment picture breaks down into two categories:
Main Line Capacity Improvements: Houston receives none. Zero. This is notable because the merger’s own projections show increased train volumes on lines running directly through the city.
Yard and Terminal Projects: Houston’s investment is concentrated almost entirely at Settegast Yard and consists of:
- Two additional 6,000-foot tracks
- Added parking stalls
That’s it.
Why it matters: Adding parking at a yard is not a capacity solution for a city that already experiences some of the worst rail blockages in the country. More trains moving through Houston with no mainline improvements means longer waits, longer blockages, and greater strain on crossings that emergency vehicles depend on.
On the “Parked Trains Aren’t on the Lines” Argument
There is a regular claim that “the trains will be parked in the yard, not on the lines in the neighborhood.”
This claim has been floated as reassurance — the idea being that if trains are staged at Settegast, they aren’t blocking crossings elsewhere.
But that’s not how a rail network works.
Trains don’t park and stay parked. They stage, load, and move through the same corridors, across the same crossings, in the same neighborhoods. Adding yard capacity without adding mainline capacity doesn’t reduce blockages. It just adds more trains waiting their turn to create them. And as Claim 2 shows, Settegast’s truck traffic is projected to increase by over 200% — meaning more activity at the yard, not less impact on the surrounding community.
Parking more trains in East Houston is not a relief. It’s concentration.
Claim 5: UP told us Houston will see fewer trains after the merger
Some Houston City Council members have relayed assurances from Union Pacific that the merger will actually result in fewer trains through Houston. It’s a reassuring claim. It’s also contradicted directly by UP’s own application.
According to STB Docket FD 36873, Filing EI-34153, projected train volume increases on major Houston corridors by Year 5 post-merger:
| Corridor | Projected Increase |
|---|---|
| Lafayette Sub (MP 353 to 327.7) | +36.7% |
| Houston Sub (Tower 87, MP 353 to 356) | +36.8% |
These aren’t peripheral corridors. The Lafayette Sub becomes the Houston Sub at Tower 87 — together they form one of the most critical freight and passenger corridors in the region. Trains traveling through Houston’s East End must wait for clearance at Towers 26 and 87, and those delays already stretch from minutes to hours, blocking grade crossings and cutting off neighborhoods from emergency response.
A 36-37% volume increase on lines already at a chokepoint isn’t an improvement. It’s the acceleration of an existing crisis
“There Are Other Ways to get to SettegasT that aren’t through the east end.”
This misses the point entirely — and not subtly.
The concern isn’t just about access to Settegast Yard. It’s about the Lafayette Sub and Houston Sub corridors, and the towers that control train clearance through the East End. Those towers, those subs, those crossings are in East Houston. There is no alternate routing around the communities that live alongside them.
Suggesting there are other ways to reach a yard doesn’t address a 36% increase in train traffic on the lines that run through your neighborhood. It just changes the subject.
Claim 6: The merger is expected to generate local economic growth through increased freight efficiency
“Economic Growth” — For Whom?
Form letters distributed to Houston elected officials promised that the UP-NS merger would generate local economic growth through increased freight efficiency. It’s the kind of language that’s easy to sign onto — until you read what UP told federal regulators.
The merger’s Operational Plan identifies specific corridors across the combined network where rail traffic is expected to increase as a result of operational optimization and the attraction of new freight. Houston was identified as the hub of one of those corridors.
And then, in the same filing, the applicants acknowledged what that means:
“Applicants recognize that this increased traffic, and other operational changes, may result in additional blocked crossings.”
Source: STB Docket FD 36873, Filing EI-34160
They know. They said so. And they filed it anyway.
Why it matters: The East End already serves as the region’s primary freight corridor — funneling traffic to ports, refineries, and petrochemical plants. That burden has never been evenly distributed across Houston. This merger intensifies it further, and the application itself acknowledges blocked crossings as an expected outcome — not a risk to be mitigated, but a consequence to be noted.
Economic growth built on the backs of communities that were never asked if the trade was worth it isn’t growth. It’s an extraction.
The Bottom Line
Across six claims, a pattern emerges. The public narrative — delivered through press releases, form letters, and council testimony — promises efficiency, environmental gains, and economic opportunity. The filings submitted to federal regulators tell a different story: increased train volumes, surging truck traffic, concentrated environmental impacts excluded from formal review, and an explicit acknowledgment that blocked crossings will get worse.
The benefits are claimed nationally. The costs are assigned locally. And the communities absorbing those costs are the same ones that have been absorbing them for decades.
We read the filings. This is what they say. And we’re making sure decision-makers can’t claim they didn’t know.
Not Another Houston 