Union Pacific Corp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Moderate Union Pacific discloses a moderate level of detail about its climate-policy lobbying. It identifies one specific piece of legislation – the federal Infrastructure Investment and Jobs Act – and refers more generally to work with the California Air Resources Board and state air-quality districts, but it does not consistently list or describe additional individual climate measures it tries to influence. By contrast, the description of how the company engages is thorough: it cites multiple routes, including direct collaboration with CARB and regional air-quality management districts, consultations with public officials through the California Council on Environmental and Economic Balance, direct federal lobbying for the Infrastructure Investment and Jobs Act, and indirect advocacy through industry bodies such as the Association of American Railroads, the U.S. Chamber of Commerce and the National Association of Manufacturers, all of which are named as targets or channels for its advocacy. The company also spells out several objectives it seeks from these efforts, such as securing market-based incentives for low- and zero-carbon technologies, promoting mode-neutral renewable-fuel programs, favouring uniform federal legislation over a patchwork of state rules, and persuading policymakers of the emissions advantages of shifting freight from road to rail. Although these aims are articulated, the company stops short of setting concrete policy parameters or quantitative targets, and the underlying policies beyond the Infrastructure Act are not individually identified, leaving some gaps in transparency. 2
Lobbying Governance
Overall Assessment Comment Score
Moderate Union Pacific demonstrates a moderate climate lobbying governance process by detailing regular reviews of trade association memberships (“reviews its participation in these organizations periodically and as memberships come up for renewal”) and committing to a “deep dive analysis into our key trade association memberships” with a report to be published in 2023. It shows alignment of both direct and indirect lobbying—“actively lobbied for the Infrastructure Investment and Jobs Act” and “actively participate in the policy-making process with these organizations” while engaging in industry bodies like the AAR Decarbonization Working Group—and has made a public commitment to align its engagement with the Paris Agreement goals (“Yes”). However, the company does not disclose any specific individual or formal body responsible for overseeing or reviewing its lobbying alignment, leaving the governance oversight role unspecified. 2