1634 Company, a Florida LLC

06/05/2026

05/23/2026

1634 supports the UP-NS merger primarily because of what it does and should do:

1) Creates a truly transcontinental freight system akin to the U.S. Interstate Highway System, but fully privately financed and operationally accountable unlike the U.S. Interstate System, and
2) Forces — or should force — a long overdue national discussion concerning the role of 1980 federal deregulation and its unintended consequences across freight transportation.

For those reasons, 1634 strongly disagrees with recent suggestions by President Donald Trump that the federal government should potentially acquire an ownership interest in Union Pacific as part of the proposed merger process.

The merger should rise or fall on its operational, competitive, economic, and public-interest merits under existing law before the Surface Transportation Board — not on political affiliation, industrial favoritism, or the prospect of federal equity participation in a privately owned freight railroad.

Railroads are already among the most heavily regulated private infrastructure systems in the United States. Unlike trucking, railroads own, maintain, dispatch, signal, police, and finance their own infrastructure while competing against a highway system whose true costs are substantially socialized through taxpayers. That imbalance is already profound. Introducing federal ownership into one participant within a supposedly competitive freight marketplace would further distort an already asymmetrical transportation environment.

More importantly, the introduction of federal equity ownership into the UP-NS proceeding would immediately undermine confidence in the integrity and independence of the STB review process itself. The Board’s legitimacy depends upon the perception and reality of procedural neutrality. If the federal government simultaneously regulates a merger while also holding a financial interest in one merger party, opponents would reasonably argue that the proceeding itself had become politically contaminated.

That would damage not only this merger review, but broader confidence in American transportation regulation.

The United States does not need nationalization-by-increment in freight rail. It needs governance modernization. Those are very different concepts.

The proper lesson of the UP-NS merger is not that government should own railroads. The proper lesson is that America has underpriced highways, fragmented freight governance, tolerated weak trucking oversight, and failed to modernize the institutional framework surrounding freight transportation since the deregulatory reforms of 1980.

The merger should trigger a national freight conversation.

It should not trigger state ownership of the supply chain.

WASHINGTON — President Donald Trump suggested in an interview with Fortune Magazine that he may want the federal government to take a stake in Union Pacific as part of its proposed merger with Norfolk Southern. The railroad merger comment came as Trump was explaining his broader views on having th...

05/22/2026

We did this today on NewsNation Chicago.

05/19/2026

A number of years ago we did some work for Safety-Kleen of Elgin IL. Our mutual goal was to find a way to put hazardous waste in containers on the intermodal rail system. We had some paperwork and logistics problems to work out as we were limited to using EPA-certified trucking companies and had to be able to follow the EPA manifests from cradle to grave.

One of the most powerful lessons learned from that experience came from Safety-Kleen's then-traffic manager. He said, “With a hazardous materials shipment transaction, ANY incident and the lawyers will come for everybody. They will always sue, looking for the deepest pockets.”

That statement landed like a powerful right hook.

With that in mind, the upshot of the recent Supreme Court of the United States ruling in Montgomery v. Caribe is this: besides the obvious insurance and vetting issues, EVERYONE involved in a transportation transaction gone bad can now find themselves dragged into court. Carrier. Broker. Shipper. Warehouse. Third-party logistics provider. Maybe the guy who answered the phone and said, “Yeah, they look legit.” Welcome to modern supply chain accountability.

For years, large portions of the transportation industry have operated under a fantasy that risk could simply be subcontracted away. Need cheaper freight? Push it downstream. Need more capacity? Hand it to a broker who hands it to another broker who found a carrier through a Gmail account, a cell phone, and a prayer. If something explodes, overturns, disappears, contaminates a neighborhood, or wipes out a family on the interstate, everybody suddenly develops amnesia and starts pointing at somebody else’s contract language.

SCOTUS may have just reminded America that federal judges can read through that nonsense. Let's see enforcement. Our industry is loaded with bad actors.

Here is the uncomfortable part for the mega-shippers: when you effectively control the transportation ecosystem through pricing pressure, appointment systems, routing requirements, scorecards, and operational mandates, you are no longer some innocent bystander “merely tendering freight.” You are part of the machine. If you profit from the machine, congratulations — plaintiffs’ attorneys will determine you belong in the lawsuit too.

Are you listening, Walmart? Do you “get it,” Amazon?

The era of hiding behind layers of disposable carriers, chameleon fleets, shell brokers, and “not our problem” legal disclaimers may be entering its sunset years.

The irony is rich. For decades, the transportation industry chased the lowest possible rate as if safety, compliance, training, insurance quality, and operational legitimacy were annoying little details standing in the way of quarterly earnings. Now the legal system may be preparing to re-price that behavior the old-fashioned American way: through litigation.

Trust me, those lawyers are still looking for the deepest pockets.

04/22/2026

Chris Burroughs is right about one thing: the system is broken. But his conclusion—that brokers shouldn’t be part of the safety conversation—is not just wrong, it’s dangerously incomplete. And it is the result of too many symposiums and cocktail parties and not enough focus on reality.

The issue isn’t that freight brokers lack authority. The issue is that federal regulation allows them to operate without meaningful safety accountability at all.

Under the current framework of the Federal Motor Carrier Safety Administration, motor carriers are subject to safety audits, inspections, and ongoing performance monitoring. Brokers are not. Motor carriers must pass a safety audit within their first year of operation. Brokers, by contrast, can obtain authority with little more than a $75,000 bond and a process agent filing.

That is not oversight. That is registration.

It creates a dangerous asymmetry: the entities physically operating trucks are scrutinized—however imperfectly—while the entities deciding which trucks get freight are never audited for safety practices, vetting standards, or operational competence.

Burroughs argues brokers shouldn’t be responsible because they don’t operate trucks. But that misses the central fact: brokers control access to freight. They choose the carrier. They set the conditions. They determine who enters the system.

Even more troubling, federal rules allow brokers to arrange transportation of hazardous materials without being held to the same safety audit regime as carriers. Hazardous materials regulations apply primarily to carriers and offerors, not to the intermediary selecting the carrier. In practice, that means companies can coordinate high-risk shipments while remaining outside the audit structure entirely.

That’s not a loophole—it’s a design flaw. And it gets worse.

A significant portion of today’s brokerage landscape operates with minimal physical presence. Using mass-registration addresses—like 30 N Gould Street in Sheridan, Wyoming—entities can obtain federal authority, post a bond, and begin transacting freight while operating remotely, often overseas. The system verifies paperwork, not reality.
So when Burroughs says brokers shouldn’t be responsible, what he’s really defending is a system where:
- Over 100,000 intermediaries exist in the market
- None are audited for safety or best practices
- Some coordinate hazardous materials, most without proper TMS systems for documenting haz mat shipments
- Many operate beyond meaningful physical or jurisdictional accountability

Meanwhile, the public shares the road with the outcome of those decisions.

This is not about assigning blame after a crash. It’s about confronting a system that outsources safety decisions to entities the government does not examine.

Brokers may not turn the wheel—but they decide who does.

Until that decision-making layer is subject to real oversight, the “blame game” Burroughs criticizes will continue—because the system itself is structured to avoid accountability.

The notion that freight brokers should be responsible for evaluating carrier safety is not only unrealistic but counterproductive.

04/17/2026

Move beyond the Wild West of trucking. Get your freight out of Dodge City — the SAFE Freight™ way. Call 630-601-3464 today.

As seen on “60 Minutes”: https://www.youtube.com/watch?v=ylbvU-lmcpI&t=320s

As seen on all TEGNA Stations: https://www.youtube.com/watch?v=PSiuscA35Cg&t=1071s

04/14/2026

1634 is proud to say "We know Rob Carpenter."

FreightWaves contributor Rob Carpenter reveals what it was like helping 60 Minutes expose Super Ego Holding as a notorious chameleon carrier network in trucking.