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FD 36873 · UNION PACIFIC CORPORATION AND UNION PACIFIC RAILROAD COMPANY—CONTROL—NORFOLK SOUTHERN CORPORATION AND NORFOLK SOUTHERN RAILWAY COMPANY

Comment EI-34316

Received or sent (printed as 9/11/2026)

Snohomish County, through its Public Works Department (“County”), is responsible for the safe disposal of municipal solid waste generated within the County. The County closed its last active landfill in June 1992 and has successfully utilized waste-by-rail services since that time. The County’s current waste disposal contractor transports the County’s solid waste in intermodal containers from Everett, WA to Roosevelt, WA, using BNSF Railway (“BN”). This waste-by-rail service utilizes a portion of the Pacific Northwest Rail Corridor (“PNRC”), specifically from Everett, WA to Vancouver, WA. A majority of the PNRC line (from Seattle, WA to Vancouver, WA) is shared by Union Pacific (“UP”). The proposed merger will have environmental impacts (i.e., impacts associated with increased rail traffic) on the shared PNRC, which will negatively impact the County’s ability to dispose of waste. The County’s waste disposal system is based on a just-in-time (“JIT”) strategy to minimize the tonnage of waste stored in transfer stations and inside loaded intermodal containers. Any delays in transit through the PNRC would be detrimental to the County. As such, the County recommends the STB require UP to invest in capital improvements along the shared PNRC to offset additional rail traffic as a result of the proposed merger.

Submitted by: David Schonhard · Snohomish County Public Works · Everett, WA

The Board publishes this comment in its environmental-comment table for this proceeding. It is quoted here as printed; nothing is inferred from it, and it states the commenter's own position in their own words, not this record's.

Permanent address docketyard.org/d/FD-36873/comment/EI-34316 · back to the docket sheet