The American Fuel & Petrochemical Manufacturers has told the Surface Transportation Board that significant competition concerns remain unresolved as the regulator's review of the proposed rail merger continues.

AFPM, which represents fuel and petrochemical manufacturers, laid out its position as the STB works through the procedural and substantive review of the transaction now before it. The association's core argument is straightforward: shippers in its sector depend on competitive rail service, and a consolidation at the scale contemplated raises the risk that dependence becomes captive.

The STB review is the gating process for any major freight railroad combination in the United States. The board must determine whether a proposed merger satisfies the public interest standard, and competition effects sit at the center of that test. AFPM's filing signals that, from the refining and petrochemical shipper perspective, the record so far does not answer the questions that matter most to them.

Petrochemical and refining shippers move large volumes of feedstocks, chemicals and finished products by rail, often over long distances and through interchange points between the major Class I networks. Consolidation can eliminate routing options, reduce the number of carriers competing for a given lane, and shift pricing power toward the surviving railroads. AFPM's stated concern is that these effects have not been adequately addressed as the review proceeds.

The association's intervention is not a final determination, and the STB has not ruled on the merits. What the filing does is keep competition questions on the record while the board continues to gather evidence, take testimony and weigh the conditions that might attach to any approval. Shipper groups historically use this phase to press for enforceable protections — gating commitments, interchange guarantees or oversight mechanisms — rather than relying on post-merger remedies.

AFPM's position carries weight with its membership because fuel and petrochemical facilities are often located where rail alternatives are limited. A refinery or chemical plant tied to one or two carriers has little leverage in rate negotiations, and merger-related changes to service patterns or routings can translate directly into higher delivered costs for those facilities. The trade group's argument ties the transaction to that cost outcome.

The STB's review continues, and the board retains discretion over scope, timeline and conditions. AFPM's submission makes clear the association expects the competition record to be tested further before any decision, and the outcome will shape how shippers, operators and regulators approach the next consolidation proposal to reach the board's docket.