The Manifest Issue 4 May 7, 2026

UP-NS Merger Application Lands at STB; FRA Deregulation Blitz Reshapes Track and Certification Rules; Crude Collapse Pressures Crude-by-Rail Economics

■ From the Field THE RAIN MAN RAILROAD There is a scene in Rain Man where Raymond Babbitt sits in an airport and refuses to board the plane

Section I

From the Field

■ From the Field

THE RAIN MAN RAILROAD

There is a scene in Rain Man where Raymond Babbitt sits in an airport and refuses to board the plane. Not because he cannot calculate the probability of a crash — he can, to the decimal point, by carrier, by route, by aircraft type. He refuses because he knows. The data is not the problem. The data is perfect. The problem is that perfect data and a functioning world are not the same thing.

On April 30th, Union Pacific and Norfolk Southern submitted their revised major merger application to the Surface Transportation Board. The filing answers the approval question. The field answers the operating question. Those are not the same question.

Every merger in the modern era of American railroading has been a geometry problem. The UP-NS combination is none of those things. Norfolk Southern runs perpendicular to Union Pacific — the eastern half of a continental system that has never had a single private owner operating an Atlantic-to-Pacific U.S. freight railroad across the existing east-west interchange structure. A leviathan. Forty-three states. Major rail hubs converted from competitive interchange points into domestic nodes inside the same operating plan.

The merged railroad will be the most internally optimized freight system ever assembled on this continent. What it will not do is adapt. And railroading — real railroading, the kind that happens at 0200 in a territory nobody in the filing has ever visited — has always been about adapting, improvising, and yes, overcoming.

The world is the variable.

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Section II

Rail & Energy Markets

■ Rail & Energy Markets
Railroad Stocks
UNP Union Pacific $264.89 -2.61 (-1.0%) CSX CSX Corp $44.46 -1.31 (-2.9%) NSC Norfolk Southern $313.39 +1.11 (+0.3%) CP CPKC $85.22 +0.22 (+0.3%) CNI Canadian National $110.84 -1.44 (-1.3%) WAB Wabtec $265.58 -4.92 (-1.8%) GBX Greenbrier $50.41 -0.59 (-1.2%) GATX GATX Corp $183.02 -16.53 (-8.3%)
Energy
CL=F WTI Crude Oil $95.69 -0.08 (-0.1%) BZ=F Brent Crude $101.27 -0.71 (-0.7%) NG=F Natural Gas $2.78 +0.05 (+2.0%)
Section III

Class I Dispatch

■ Class I Dispatch
BNSF
This document provides the public notice that by letter received September 2, 2025, BNSF Railway (BNSF) petitioned FRA for an amendment from existing relief from certain regulation
via FRA — Fed Register
Union Pacific
via Yahoo Finance — Transport
CSX
This document provides the public with notice that, on April 21, 2026, the Massachusetts Bay Transportation Authority (MBTA), as the host railroad, submitted a request to permit CS
via FRA — Fed Register
Norfolk Southern
This document provides the public notice that Norfolk Southern Railway Company (NS) petitioned FRA for relief from certain regulations concerning training requirements.
via FRA — Fed Register
Canadian National

CN has recognized 194 customers with Safe Handling Awards for demonstrating “excellence in the safe loading and transportation of regulated products by rail” in 2025. The Class

via Railway Age
Section V

Intelligence Briefing

■ REGULATORY
UP-NS Merger Filing Arrives at the STB — and the Real Fight Is Over What 'Complete' Means
The Surface Transportation Board confirmed receipt of a revised major merger application from Union Pacific and Norfolk Southern, setting deadlines for public comment on whether the filing is procedurally complete. That procedural gate matters more than most observers realize. Under the STB's 2001 major merger rules — written in the aftermath of the BN-SF and UP-SP service meltdowns — a completeness challenge is the first and most effective lever available to opposing parties. Competing carriers, shipper coalitions, and labor organizations will argue that the application's competitive analysis, operating plan, and service commitments are insufficient to trigger the formal review clock. If the Board agrees, UP-NS goes back to the drafting table, buying opponents months. If the Board deems it complete, a roughly 30-month review process begins — one that will consume STB bandwidth and force every Class I, short line, and captive shipper in the eastern and western halves of the network to model what a transcontinental railroad actually means for their traffic. The revised filing suggests the original submission had deficiencies the carriers chose to address preemptively rather than risk a Board rejection. For railroad operations professionals, the key document to watch is the operating plan: how UP and NS propose to integrate dispatching, crew districts, and terminal operations across what are currently two entirely separate railroad cultures. That plan will tell you more about the merger's viability than any financial projection.
■ REGULATORY
FRA's April Deregulatory Blitz: A Dozen Rules Changed, and the Pattern Is Clear
In the final week of April, FRA published an extraordinary batch of final and proposed rules that collectively lighten the regulatory burden on railroads across track maintenance, certification, enforcement, and reporting. The list includes repealing the track surface runoff parameter, eliminating transitional bridge load-capacity evaluation schedules, allowing electronic engineer and conductor certificates, codifying C3RS waiver relief, granting prosecutorial discretion to decline technical violations, permitting electronic injury posting, and easing quiet-zone curb requirements. Taken individually, each action is defensible housekeeping. Taken together, they represent a deliberate philosophical shift: FRA is moving from prescriptive compliance toward performance-based regulation, trusting railroads to meet safety outcomes without specifying the method. For maintenance-of-way supervisors, the track surface repeal means one less geometry parameter to chase during surfacing programs — though the underlying Class standards still govern. For operating officers, electronic certificates mean crews no longer risk decertification over a laminated card left in another grip. For compliance departments, the prosecutorial discretion notice is the most consequential: it signals that FRA enforcement attorneys will focus resources on violations with real safety consequences rather than paperwork deficiencies. Short lines, which have always borne a disproportionate compliance burden relative to their risk profile, stand to benefit most.
■ MARKET
Crude Oil's Plunge on US-Iran Optimism Puts Crude-by-Rail and Fuel Surcharge Revenue in Play
Crude oil prices fell sharply on reports of progress toward a US-Iran diplomatic resolution, a development that ripples through railroad economics on two fronts. First, the direct volume question: crude-by-rail loadings, which had been climbing modestly as Permian and Bakken production outpaced pipeline takeaway in certain corridors, lose their economic rationale when prices drop below the threshold where pipeline tariffs plus rail differentials make sense. BNSF and CP Kansas City, the two carriers most exposed to crude unit-train traffic, will watch origin loading patterns closely over the next 30 days. Second, and more broadly significant, is the fuel surcharge mechanism. Every Class I recovers a substantial portion of diesel cost through contractual fuel surcharges tied to benchmark crude or highway diesel indices. When crude drops fast, those surcharges recalibrate downward — meaning railroad revenue per carload falls even if volume holds steady. For shippers, lower fuel surcharges reduce total transportation cost and can narrow the gap between rail and truck pricing, potentially shifting marginal loads to highway. For short lines that pass through fuel surcharges from their Class I connections, the revenue hit arrives with a lag but still lands. The operational takeaway: falling crude helps the economy broadly but squeezes railroad revenue intensity at the margins.
■ CAPITAL
$2 Billion CRISI Grant Cycle Opens — and the Competition Will Be Fierce
FRA's announcement of up to $2.04 billion in Consolidated Rail Infrastructure and Safety Improvements program funding for FY 2025-2026 represents the largest CRISI cycle to date, and the money will be oversubscribed by a factor of at least three. CRISI has become the primary federal funding vehicle for short line rehabilitation, grade crossing improvements, and rail-served industrial access projects — the kind of infrastructure that Class I capital budgets do not touch. For short line operators, this funding cycle is the best chance in a generation to upgrade bridge load ratings, relay rail to 136-pound, and build or extend sidings that unlock capacity. But CRISI's competitive structure rewards applications with strong benefit-cost analyses, committed local match, and clear safety narratives. States with dedicated rail planning offices — Pennsylvania, Virginia, Ohio, North Carolina — consistently outperform because they have the institutional capacity to assemble competitive applications. States without that infrastructure leave money on the table. The operational reality is that CRISI dollars eventually become tonnage: every rehabilitated short line bridge, every new siding, every crossing elimination translates to carloads that would otherwise move by truck or not move at all. Railroads and state DOTs that start application development now, rather than waiting for the deadline, will capture a disproportionate share.
■ TECHNOLOGY
Loram-One Big Circle Partnership Signals the Mainstreaming of Continuous Rail Monitoring
Loram's strategic partnership with UK-based One Big Circle to deploy intelligent rail monitoring technology globally marks a significant step in the migration from periodic manual inspection to continuous digital assessment. One Big Circle's platform uses onboard cameras and machine learning to detect rail surface defects, gauge anomalies, and infrastructure encroachments from revenue service or dedicated inspection vehicles. Loram, already the dominant North American provider of rail grinding, ballast maintenance, and rail inspection services, gains a digital layer that complements its physical fleet. The field significance is straightforward: traditional rail inspection relies on detector cars operating on scheduled frequencies — every 30, 60, or 90 days depending on track class and tonnage. Between passes, defects develop undetected. Continuous monitoring from revenue trains or hi-rail vehicles closes that gap, catching defects days or weeks earlier. For track supervisors, the transition means shifting from calendar-based inspection to condition-based maintenance — a change that requires new workflows, new data management skills, and new relationships between signal, track, and operations departments. For Class I chief engineers, the question is whether continuous monitoring data can eventually satisfy FRA inspection requirements, reducing the need for dedicated detector car runs. FRA's current deregulatory posture suggests that conversation is coming sooner than many expect.
■ SAFETY
Wheel-Rail Profile Research at MxV Pueblo Quantifies What Track Engineers Already Know
MxV Rail's latest research on how wheel and rail profiles affect hunting stability at speed, published in the May Railway Age R&D feature, puts empirical data behind a phenomenon that anyone who has ridden the head end above 50 mph on tangent track understands viscerally. Hunting — the lateral oscillation of a wheelset between the rails — is a function of conicity, truck suspension, rail profile, and speed. When profiles wear beyond design parameters, hunting onset speed drops, and what was stable at 60 mph becomes unstable at 50. The consequences range from lading damage and rider discomfort to, in extreme cases, flange-climb derailment. What makes this research operationally useful is the quantification of profile wear thresholds. Railroads already re-profile wheels on mileage or time intervals, and grind rail to restore transverse contour. But the interaction between the two — which combination of worn wheel and ground rail produces the worst hunting behavior — has been poorly characterized outside of simulation. MxV's test track work at Pueblo provides measured data that can inform both wheel-shop turnback criteria and rail grinding templates. For intermodal carriers running stack trains at track speed across thousands of tangent miles, even a modest improvement in hunting onset velocity translates directly to reduced slow orders, fewer lading claims, and longer component life. The research matters most where it is least glamorous: in the grinding program spreadsheet.
■ LABOR
Two More Short Lines Petition for One-Person Crews — the Precedent Factory Is Running
Georgia Central Railway and First Coast Railroad have both filed FRA petitions for special approval to operate with one-person train crews, adding to what is now a steady accumulation of short-line applications under the current crew-size framework. Neither petition is surprising in isolation — both are low-density, low-speed operations where a single-crew-member model is arguably safer than stretching a thin labor pool across two-person assignments with fatigued or undertrained second crew members. But the cumulative effect of these petitions is building a body of approved precedent that will become increasingly difficult for labor organizations to contest on a case-by-case basis. Each approval establishes operational parameters — maximum speed, train length, hazmat restrictions, communication requirements — that the next applicant can point to as proven and safe. For Class I carriers, the short-line petition wave is a proxy war. The railroads cannot directly petition for system-wide one-person operations under current rules, but every short-line approval chips away at the argument that two-person crews are an inherent safety requirement. SMART-TD and BLET understand this dynamic, which is why opposition filings on even the smallest short-line petition tend to be detailed and aggressive. The real question is whether FRA will eventually issue a programmatic determination rather than continuing to adjudicate one railroad at a time.
■ TECHNOLOGY
Holland's Welding-Lifecycle Approach Reframes Rail Sustainability as Maintenance Economics
Holland's articulation of rail sustainability through advanced welding technologies — extending rail life, reducing scrap, and minimizing energy consumption per weld — reframes the environmental conversation in terms that track maintenance budgets actually respond to. The rail industry's sustainability discourse tends to cluster around locomotive emissions and modal shift calculations, both legitimate but disconnected from the daily reality of a division engineer managing 500 miles of mainline. Where sustainability hits the track structure is in the decision to grind and weld versus pull and relay. Every year of extended rail life means deferred capital expenditure, reduced scrap steel processing, and fewer work windows consuming track time. Holland's thermite and flash-butt welding technologies, combined with rail repair welding systems that rebuild defective rail in place, directly address the largest material cost in track maintenance after ballast. The operational question is how far repair welding can push the envelope before metallurgical fatigue makes relay the only responsible option. That boundary varies with tonnage, curvature, temperature range, and rail chemistry — and it is the kind of engineering judgment that no amount of corporate sustainability messaging can replace. For short lines running legacy 115-pound or 119-pound rail, repair welding is often the difference between keeping a line in service and abandoning it. Holland's technology portfolio matters most where the capital budget is thinnest.
■ MARKET
Amazon's Trucking Expansion Rattles Logistics Stocks — and Should Get Rail Intermodal's Attention
Universal Logistics Holdings saw its stock plunge after Amazon announced an expansion of its proprietary trucking fleet, a development that reverberates well beyond the truckload sector. Amazon's in-sourcing of linehaul capacity has been methodical: first last-mile delivery, then regional distribution, now long-haul trucking. Each step reduces the volume available to for-hire carriers — and to rail intermodal. The railroad connection is direct. Intermodal containers moving between Amazon fulfillment centers have been a growth driver for Class I domestic intermodal networks, particularly at BNSF and J.B. Hunt's intermodal division (which rides primarily on BNSF and CSX). When Amazon controls its own trucks, it can optimize routing in ways that bypass intermodal entirely for lanes under 1,000 miles — precisely the lanes where truck-to-rail conversion has been most competitive. For longer lanes, Amazon's truck fleet still cannot match rail economics, but the threshold distance at which rail wins extends further as Amazon's trucking scale drives down its per-mile cost. The downstream effect for railroads is a narrowing of the addressable intermodal market. Class I commercial teams that have built growth projections around e-commerce containerization need to disaggregate Amazon volume from the total market and model it as at-risk. The shippers who remain loyal to intermodal will be those without Amazon's capital — mid-market retailers and consumer goods companies for whom the rail cost advantage remains decisive.
■ CAPITAL
$1.15 Billion in Crossing Elimination Grants Target the Most Dangerous Intersection on Any Railroad
FRA's Railroad Crossing Elimination Program NOFO for FY 2025-2026 makes available up to $1.15 billion for grade separation, closure, and safety improvement projects — funding that addresses the single deadliest interface on any railroad: the highway-rail grade crossing. There are roughly 130,000 public at-grade crossings in the United States, and despite decades of improvement, they remain the site of the majority of railroad-related fatalities. Crossing elimination — physically separating road and rail through overpasses, underpasses, or road closures — is the only permanent solution, but the cost per crossing typically ranges from $5 million for a simple rural grade separation to $50 million or more in urban environments. The $1.15 billion sounds substantial but will fund perhaps 50 to 150 projects depending on complexity, out of thousands that need attention. For railroads, crossing elimination delivers direct operational benefit: fewer trespasser incidents that trigger hours-long FRA investigations and service disruptions, reduced horn noise complaints that drive political pressure, and in some cases elimination of speed restrictions imposed by crossing conditions. Communities adjacent to Class I mainlines, where train frequency has increased as precision scheduled railroading concentrated traffic on fewer routes, have the strongest safety case. The program's competitive structure means that communities with existing engineering studies and committed local match will again outperform those starting from scratch.
■ SAFETY
BNSF's AFM Indicator Calibration Waiver Amendment Reveals a Quiet Braking-System Maintenance Debate
BNSF's petition to amend its existing FRA waiver on air flow method indicator calibration may read as narrow technical relief, but it points to a broader tension in freight car brake system maintenance. AFM indicators measure the rate of airflow through a brake pipe, and their calibration determines whether a car-by-car brake test accurately identifies malfunctioning brake equipment. When calibration tolerances drift, the test can pass a car with a defective control valve or fail a car that is functioning within design limits — both outcomes that degrade either safety or operational efficiency. BNSF's original waiver, and now this amendment request, likely seeks flexibility on calibration intervals or methods, reflecting the reality that maintaining thousands of AFM devices across a continent-spanning network to a single prescriptive standard is logistically challenging. The broader issue is that freight car brake technology has not fundamentally changed since the adoption of the ABD valve, while the trains those brakes are expected to stop have gotten longer and heavier. Electronically controlled pneumatic brakes (ECP) offered a solution but were abandoned after the ECP mandate was rescinded. What remains is an aging pneumatic system maintained to rules written for shorter trains, and periodic waiver relief is how railroads manage the gap between regulation and operating reality. For carmen and mechanical officers, this petition is a reminder that brake system maintenance remains the most consequential and least automated function in the car shop.
■ GENERAL
UP's SD60M at Beverly Yard: A Snapshot of What Regional Switching Actually Looks Like
A Trainorders post documenting UP SD60M 2292 working the Beverly yard job out of Cedar Rapids offers a useful window into the unglamorous reality of Class I local operations — the kind of work that keeps carloads moving but rarely appears in investor presentations. The Beverly operation described — a Clinton-to-Beverly turn setting off westbound traffic blocks, with a yard job subsequently switching and building outbound trains — is the connective tissue between mainline train operations and the customers who actually generate revenue. Every precision scheduled railroading plan depends on local jobs like YBV53 running reliably, on time, with enough crew starts and power to handle the volume. The assignment of an SD60M to this work is itself notable. The SD60M fleet, built between 1989 and 1994, is deep into its twilight years on most Class I rosters. These units persist in yard and local service because their 3,800 horsepower is more than adequate for switching and short-haul turns, and their retirement would require either capital expenditure on replacement power or further consolidation of local jobs — which means fewer switching opportunities, longer car dwell, and worse service for the customers on those branches. For short line operators who interchange with UP in Iowa, the health and frequency of these local turns directly determines how quickly their traffic gets into the mainline pipeline. When local jobs get annulled for crew shortages or power failures, it is the short line's customer who waits.
Section IX

On the Labor Front

■ On the Labor Front
SMART-TD
Georgia Central Railway's one-person crew petition directly implicates the SMART-TD bargaining position that conductor work is safety-critical and cannot be eliminated by regulatory fiat. Each short-line approval erodes the labor argument that two-person operations are a universal safety floor, and the unions face a strategic choice between fighting every petition individually or negotiating a framework that trades crew-size flexibility for compensation guarantees.
BLET
FRA's codification of C3RS waiver relief into permanent certification rules gives BLET and SMART-TD members formal protection from decertification when close-call incidents are reported through the confidential system. This matters on the ground because the fear of losing one's certificate has historically been the single biggest deterrent to honest safety reporting — and the new rule removes that chilling effect for participating properties.
General
FRA's move to allow electronic engineer and conductor certificates eliminates a persistent irritant for operating crews who have faced decertification threats over lost or damaged physical cards. The rule change also streamlines railroad compliance departments, which have spent disproportionate administrative time reissuing certificates — but unions should verify that electronic systems include adequate protections against employer access to certification data beyond what is operationally necessary.
Section X

Regulatory Wire

■ Regulatory Wire
FRA
MBTA's request for FRA approval to begin CSX PTC field testing on its Fitchburg and Haverhill lines reflects the ongoing challenge of interoperability between commuter and freight PTC systems. CSX locomotives operating on MBTA territory must communicate seamlessly with MBTA's train control infrastructure — a technical integration that has proven difficult on shared-use corridors nationwide and will be closely watched as a model for other commuter properties still working toward full PTC implementation.
FRA
FRA's formal grant of prosecutorial discretion to enforcement attorneys to dismiss technical violations without practical safety significance is a paradigm shift for railroad compliance culture. For decades, railroads have devoted substantial resources to defending citations for paperwork errors and minor procedural deviations; this notice signals that FRA intends to redirect enforcement bandwidth toward violations that actually endanger people.
PHMSA
PHMSA's proposal to explicitly allow drones and satellite imagery for pipeline right-of-way patrols has implications for rail-adjacent corridors where pipelines and railroads share easements. If remote sensing becomes the standard for pipeline patrol, the technology and regulatory precedent could accelerate FRA's own consideration of aerial and remote inspection methods for railroad rights-of-way — a conversation already underway informally within the track inspection community.
Section XI

Equipment & Fleet

■ Equipment & Fleet
LOCOMOTIVE
Siemens Mobility's delivery of its 100th Vectron locomotive to Polish operators illustrates the widening gap between European and North American locomotive procurement models. European railroads — including freight operators — are buying modular, multi-system electric and diesel-electric platforms designed for cross-border interoperability, while North American Class I fleets remain locked into single-source DC traction diesel purchases. The Vectron platform's flexibility may eventually inform North American discussions about next-generation motive power, particularly as electrification corridors and dual-mode requirements expand.
RAILCAR
Durbin & Greenbrier Valley Railroad's petition for extension of stenciling and safety glazing waivers on heritage passenger equipment highlights the ongoing tension between FRA equipment standards written for interchange-capable freight and passenger rolling stock and the operational reality of tourist and excursion railroads running captive fleets. FRA's recent rule removing stenciling requirements for non-interchanged tourist freight cars addresses part of this problem, but passenger car glazing standards remain a significant compliance burden for heritage operators.
RAILCAR
FRA's formal exemption of tourist and excursion freight cars from restricted-car stenciling when not interchanged eliminates a compliance burden that had no safety rationale — these cars never enter the general interchange fleet and pose no identification risk to connecting carriers. The rule change is a small but meaningful win for heritage and scenic railroads that have spent years seeking parity with the risk their operations actually present.
Section XIII

Railroading Quote

■ Railroading Quote of the Week
The secret of success is to do the common thing uncommonly well.
— John D. Rockefeller Jr.
Industrialist