Preserving the Environment

Union Pacific recognizes that we must preserve the environment in which we operate. We believe that any long-term approach to climate change must include measures that fuse a reduced carbon footprint together with economic growth and prosperity. That is why we do our part to protect the environment, while enabling a strong, sustainable and resilient economy that can respond with innovation in the face of challenges.

The Association of American Railroads has determined that if just 10 percent of the nation's long-haul freight currently moving on highways was diverted to rail, 1 billion gallons of fuel would be saved and greenhouse gas emissions would decrease by 10 million tons. Union Pacific seeks to protect the earth in ways that extend beyond the competitive environmental advantage that trains offer. We invest in technology and training, and we continue to actively work to reduce the impacts of our operations.

Highlights, Challenges and Opportunities

Union Pacific improved locomotive fuel efficiency in 2014 and building upon that, we strive to meet our new goal of a 1 percent annual reduction in our locomotive emissions rate from 2015 through 2017.

We completed CDP's water questionnaire for the first time, understanding that this is an issue of rising importance for our stakeholders. Our collaborations also continued to bear fruit, ranging from working with the Environmental Defense Fund (EDF) through its Climate Corps Program to working with suppliers to further reduce locomotive emissions.

Union Pacific recognizes the opportunities that technology offers in environmental management. We pride ourselves on investing capital back into the company, and we remain mindful of our environmental impacts as we explore new capabilities that lead to business success.

Addressing Climate Risk

Union Pacific proactively assesses the risk climate change poses to our operations.

We are strengthening our railroad's ability to withstand future changes and events that might be associated with climate change. Temperature extremes could create a harsher work environment for employees who work outside, increase rail maintenance costs and impact service by decreasing the velocity of operations. In addition, severe weather events, such as hurricanes, could impact Union Pacific's network by necessitating slower speeds, which would lead to service interruptions, or by increasing track repair and recovery costs.

Union Pacific educates the public and elected officials about how the rail industry's growth can mitigate some climate change impacts. We also work closely with public agencies to study and advance technology that will reduce emissions from our network and in our yards. For instance, we strategically locate the newest, lowestemitting locomotives in parts of the country with air quality challenges.

In addition, Union Pacific uses an Enterprise Risk Management process to incorporate input from several internal departments, including Strategic Planning, Operations, Law and the Environmental Management Group, to identify potential climate change risks and opportunities. Each department plays a role in managing risks and opportunities and evaluating materiality and priorities.

Oversight for sustainability issues is taken seriously at Union Pacific. Our vice president of safety, security and environment and chief safety officer has direct responsibility for Union Pacific's progress and status regarding climate change, and reports directly to the board of directors at least annually regarding the company's implementation of its environmental policy, including its activities related to climate change. The vice president of safety, security and environment also reports directly to the chief executive officer and president regarding compliance with the company's environmental policy.

We continue exploring new ways to reduce our fuel consumption by developing innovative locomotive technology, strengthening locomotive engineer training and teaching employees to conserve.

For additional information on how climate change could have a material adverse effect on our operational results, financial condition and liquidity, see the risk factors in our Annual Report on Form 10-K.

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Environmental Management

For the good of our business, earth and communities, we strive to maintain our leadership role in providing safe, reliable, fuel-efficient and environmentally responsible transportation of the goods families and businesses need.

Our Environmental Management Group, which oversees Union Pacific's compliance with environmental laws and regulations through our Environmental Management System, is strategically integrated into the company's daily operations.

Ensuring that best practices are followed to reduce environmental impact requires planning, coordination and communication – and employees' hands-on involvement and awareness.

To support railroad operations, Union Pacific's environmental management efforts begin with our Environmental Policy as signed by our CEO. The policy applies to all aspects of our operation and outlines three primary commitments every employee must make:

  • Pollution prevention
  • Regulatory compliance
  • Continuous improvement

These actions ensure that we align our environmental focus with our overall corporate mission of service – working for the good of employees, customers, shareholders and the communities we serve and call home. To ensure accurate reporting of our environmental performance, we use sophisticated systems and programs that track detailed metrics. The goal is to ensure we meet or exceed all applicable laws regulating our environmental impact. Our environmental management mission is:

  • Prevention. Prevent the causes of environmental damage that result from operations.
  • Preparedness. Align with internal and external customers to prepare for effective response and tomorrow's environmental issues.
  • Response. Respond to emergencies involving environmentally sensitive materials to minimize health, environmental, operational and financial impact.
  • Recovery. Restore the environment as a result of contamination for which Union Pacific is responsible.
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Greenhouse Gas Emissions

As part of our efforts to address climate change, Union Pacific has committed to reduce locomotive fuel consumption, which accounts for nearly all of our greenhouse gas (GHG) emissions. We demonstrated this commitment in 2011 by setting our first goal to reduce our fuel consumption rate 1 percent annually from 2011 through 2015.

We encountered challenges progressing toward this initial goal, driven primarily by a change in our freight traffic mix. We did, however, decrease our fuel consumption rate by 1 percent in 2014 compared to 2013, finding new opportunities to reduce waste and continuing to deploy technologies that assist the locomotive engineer in saving fuel and that optimize train scheduling.

In goal setting, the company aims for the appropriate balance between financial returns, environmental performance and social commitment. We use operational and technological improvements to drive the majority of our greenhouse gas emissions reductions.

We believe the annual 1 percent reduction remains a viable objective as we forecast business and fuel saving initiatives, and have restated this as our goal from 2015 to 2017.

Reducing our fuel consumption remains a corporate priority. Senior leadership is focused on this objective, and success is directly tied to compensation based on our performance review process.

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Sustainability Report 2015 - Environment Highlights

Our Performance

Union Pacific produced a total of 12,666,733 metric tons of GHG emissions from fossil fuels in 2014, which is up from 2013, due primarily to an increase in volume.

Union Pacific's emissions from biomass sources were 87,744 metric tons.

Scope 3 emissions from employee travel totaled 19,977 metric tons. Employee travel includes rental car fuel and commercial air travel. We worked with suppliers to identify their Scope 3 emissions on behalf of Union Pacific. Suppliers representing an estimated 27 percent of our Scope 3 spend, with emissions totaling 321,843 metric tons in 2014 compared to 262,355 in 2013.

Union Pacific's 2014 greenhouse gas inventory was verified by Conestoga-Rovers & Associates. Union Pacific works with Trinity Consultants to compile our GHG inventory. Conestoga-Rovers & Associates and Trinity Consultants are independent organizations.

Union Pacific named to CDP's Carbon Disclosure Leadership Index

Union Pacific Railroad achieved its best performance in CDP's Standard & Poor's 500 (S&P 500) climate change 2014 report for the depth and quality of climate change data it disclosed. With a carbon disclosure score of 99 out of a possible 100, Union Pacific had the highest score among railroads. It also ranked in the top 10 percent of all companies in the S&P 500 sample, securing a place on the Climate Disclosure Leadership Index.

In its sixth annual CDP disclosure, Union Pacific highlights technology, training and operational innovations designed to increase fuel efficiency. We also completed CDP's water questionnaire for the first time, which helped us further understand the breadth of our relationship to water. The survey looks at our water use, as well as that of our customers and suppliers. We view participation in this survey as part of a helpful dialogue for understanding impacts on the issue of water.

Sustainability Report 2015 - Environment CDP logo
Sustainability Report 2015 - Environment Reducing Emissions

Reducing Customers' Emissions

Union Pacific customers helped eliminate an estimated 35.8 million metric tons of greenhouse gases by choosing rail over truck transportation for their shipping needs.

Through our Carbon Emissions Estimator, our customers can calculate the carbon emissions reduced when they ship goods with us. We also send customers a savings estimate for their shipments.

Increasing Fuel Efficiency

Improving our fuel efficiency is an important part of Union Pacific's sustainability actions. Union Pacific has a multi-disciplinary locomotive fuel conservation team and emissions reduction team that meet monthly and focus in part on addressing emissions from our locomotives. Diesel fuel accounts for more than 20 percent of operating expenses, which means increasing efficiency is good for the environment and also improves our bottom line. It allows us to manage price volatility and supports the transition to a lower carbon economy.

In 2000, we could move a ton of freight 375 miles on average on one gallon of diesel fuel. By 2010, we were able to move it 495 miles. Due to changing business conditions, our efficiency rate declined to 471 miles per gallon in 2013, then increased to 475 miles in 2014 as multiple initiatives brought improved results. We continue to look for innovative ways to increase fuel efficiency, while growing as a business.

We approach fuel efficiency in our locomotive fleet through a three-pronged approach:

  • Engaging employees
  • Improving operations
  • Incorporating technology
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Engaging Employees

The first step in our fuel efficiency strategy is the most basic but perhaps the most important: engaging with the employees who operate our locomotives and manage our infrastructure. Because of our investment in training and coaching on the systems we operate, our employees are able to hone their train operating techniques while saving fuel.

As a company, we continue to implement and test onboard Energy Management Systems that our employees are trained to use. Among the most advanced are:

LEADER (Locomotive Engineer Assist/Display and Event Recorder)

LEADER analyzes train operations through advanced GPS maps and provides throttle and brake prompts. Rolled out in late 2012, LEADER is now on more than 470 locomotives, running on more than 6,500 route miles.

Trip Optimizer (TO)

Similar to a vehicle's cruise control system, TO automatically controls a locomotive's throttle, which helps keep trains on schedule while minimizing fuel use. The TO system calculates the most efficient way of running by considering factors such as train length, weight, grade, track conditions, weather and locomotive performance. TO is now on 390 locomotives, running on more than 5,780 route miles.

Smart Consist

This system provides the locomotive engineer requested horsepower and tractive effort for the locomotive consist by selecting throttle notch combinations for the best fuel economy. More than 210 locomotives are equipped with this technology, which is enabled systemwide.

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Improving Operations

Since 2000, Union Pacific has invested about $7.5 billion to purchase more than 4,100 locomotives that meet the U.S. Environmental Protection Agency's Tier 0, Tier 1, Tier 2 or Tier 3 guidelines, including 261 purchased in 2014 and 100 in 2013. During this period, Union Pacific retired more than 3,000 older, less-efficient locomotives. We also have been working hard to revitalize rather than dispose of existing infrastructure. As part of those efforts, Union Pacific has overhauled or rebuilt more than 5,800 diesel engines with emissions control upgrades.

Additionally, 94 percent of our locomotives are certified under existing U.S. EPA Tier 0, Tier 1, Tier 2 or Tier 3 emissions standards, which progressively add more stringent limits on engine air emissions.

Our investments in new "switching" locomotives, which are designed to move trains or cars within a rail yard, also have helped improve fuel efficiency.

Locomotive Technology Decreases Fuel Consumption

A. The cab display provides the locomotive engineer information to manage the train's energy. When combined with Positive Train Control, a federally mandated rail safety system, the cab will provide advance notification for signal and speed restrictions, helping a locomotive engineer plan train movement across the territory.

B. The wattmeter directly measures the amount of electrical energy produced by a locomotive, which helps determine how much fuel is used to generate motive power.

C. The fuel meter electronically measures locomotive fuel usage and reports the data via radio to assist with fuel planning. A typical road locomotive has a maximum fuel capacity of 5,000 gallons.

D. The Ancillary Card Cage (ACC) provides the processing power, communications and data collection capabilities to support the industry's fuel conservation efforts. Each equipped locomotive transmits about 100 megabytes of data per month (about 400 books), which equates to about one terabyte per month (about 4.5 million books) for the entire Union Pacific fleet.

E. GPS transmitter – During a train trip, a sophisticated network of onboard computers and GPS sync up to track profiles (grade and curves) with train length, weight and locomotive performance. It continuously calculates and updates algorithms, adjusting for changing terrain to ensure the most efficient braking and operations.

F. An antenna farm combines a locomotive's external communications devices into a single replaceable roof-mounted package. It transmits information that helps measure the positive impact of an Energy Management System on Union Pacific's fuel cost.

G. 220 MHz Radio – A locomotive's Energy Management System uses four radios to receive detailed information about its overall performance, providing timely data to enhance fuel efficiency and increase velocity.

H. The sensor package is used to optimize fuel usage. Electrical and pneumatic sensors monitor in-train forces, tractive effort, acceleration and air brake status, and relay the information to the train's Energy Management System.

I. The Train Management Computer (TMC) is a host for the locomotive's Positive Train Control and Energy Management Systems. The TMC conveys movement-related information and authority from our train dispatching center to the train's onboard train-control system. The system assists a locomotive engineer by providing reminders about proper speeds, movement limits and required stopping distances.

J. An event recorder measures an Energy Management System's efficiency, enabling Union Pacific to calculate the effect of in-train forces, braking effort, acceleration, steep grades and curve on a train.

Incorporating Technology

Sustainability Report 2015 - Environment Incorporating Technology

Taking advantage of the best available technology helps us maintain our strengths as a company and enables us to innovate more advanced ways to operate trains efficiently. For years, Union Pacific has set the standard for railroads nationwide in locomotive technology and research. We work with stakeholders, including suppliers, governmental organizations, employees, engineering researchers and others, as we explore and advance technological improvements in our locomotive fleet.

We continue to partner with Electro-Motive Diesel to evaluate exhaust gas recirculation (EGR), diesel oxidation catalysts and diesel particulate filters on the experimental UP 9900 locomotive, the signature unit in a series of 10 experimental emissions-reducing SD59MX locomotives. Union Pacific's experimental SD59MX locomotives are the first diesel locomotives worldwide to be equipped with EGR technology.

After more than three years operating in California, UP 9900 recently was evaluated for testing and analysis. Results were positive regarding anticipated condition and usage.

UP's investments in the technology support the industry's move toward the U.S. Environmental Protection Agency's (EPA) more stringent Tier 4 air emissions standards.

Tier 4 emissions standards for locomotives purchased after 2014 are only strengthening our commitment to environmental performance. Union Pacific is actively collaborating with locomotive manufacturers in the research and development of new technology that meets these requirements.

Evaluating Alternative Fuels

For more than half a century, Union Pacific has explored alternative fuels including bio-diesel, propane, liquefied natural gas (LNG) and hydrogen. As early as 1952, Union Pacific kicked off a project using gas turbine-electric locomotives, and we remain the only major railroad worldwide with extensive gas turbine experience.

We continue to study the benefits of converting locomotives to LNG fuel, which emits fewer greenhouse gas emissions than diesel fuel. See Union Pacific and Liquefied Natural Gas for factors we consider as we determine whether LNG fuel is a commercially reliable and economical option. North American railroads operate the world's only integrated freight rail system, which means that a significant portion of our business goes onto other railroads and vice versa. As we evaluate use of alternative fuels, we also must protect the reliability of this integrated network.

Collaborative Opportunities

California Air Resources Board and California Air Districts

Union Pacific continues to work with the California Air Resources Board (CARB) and California's regulatory air districts to reduce emissions and improve air quality. Our collaboration with CARB began in the mid-1990s on a first-of-its-kind commitment to bring the most advanced and environmentally friendly locomotive technology to the South Coast Air Basin by 2010, with a continuing commitment through 2030.

Union Pacific facilitates dialogue to broaden awareness of environmental challenges as CARB and other relevant entities consider future steps. In 2014, that included working with supply chain partners to provide CARB's executive officer with a tour of Union Pacific's Intermodal Container Transfer Facility in Long Beach, California. The tour included representatives from ocean shipping, trucking and railroads and highlighted the complexity and efficiency of the goods movement system.

Union Pacific also hosted University of Illinois graduate students whom CARB has retained to explore the feasibility of operating with multiple locomotive types.

California Council for Environmental and Economic Balance

The California Council for Environmental and Economic Balance (CCEEB) has worked since 1973 to solve the most pressing environmental policy problems facing California. CCEEB is a nonprofit, non-partisan coalition of industry, labor and public leaders dedicated to making environmental and economic balance a reality. Union Pacific has been a member and has had an employee serving on CCEEB's board since 1992.

Global Environmental Management Initiative (GEMI)

Union Pacific has been a member of the Global Environmental Management Initiative (GEMI) since 2010. GEMI brings together companies from diverse industries to solve environmental problems and provide tools for the public's use. One of our employees served on the GEMI board, and we helped GEMI launch a new set of tools called Quick Guides. See more at GEMI's website.

See Community and Collaboration for more information about Union Pacific's collaboration with public and private sector organizations.

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Conserving Energy

Locomotive diesel fuels account for 93 percent of our greenhouse gas emissions from fossil fuels, so related operational and technological improvements drive the majority of our greenhouse gas emissions reductions. Vehicles and electricity drive the greatest amount of other emissions.

Recognizing that energy use has both an environmental and business cost, Union Pacific has made efforts to conserve and reduce energy use at our facilities. Our Omaha, Nebraska, headquarters is LEED-EB Silver certified. Since initial occupancy in 2004, Union Pacific Center has maintained the U.S. Environmental Protection Agency's Energy Star designation, routinely implementing further energy conservation actions.

Additional energy conservation and reduction initiatives include:

  • Union Pacific's Utility Management Team completed 45 utility conservation projects in 2014, ranging from upgrading facility lighting and air compressor systems to installing more energy-efficient HVAC systems. Energy saved from these projects is equivalent to that consumed by more than 260 U.S. homes annually.
  • More than 400 outdated locomotive repair pit lights were replaced with energy efficient LED fixtures. The new lights increase safety and decrease energy and maintenance costs.
  • We collaborated with the Environmental Defense Fund Climate Corps Program. Our 2014 fellow created a strategy to replace inefficient high-pressure sodium lights in maintenance shops and developed a plan to install electric sub-meters in locomotive maintenance facilities, tracking energy efficiency improvements and identifying savings opportunities. Our fellow also conducted a locomotive load testing study to determine potential fuel savings, while maintaining networkwide operating efficiency. Load testing involves running the locomotive at the highest throttle to find unit defects.
  • More than 600 "Machine Shut Off" decals were installed networkwide on equipment to serve as a conservation reminder to employees.

Union Pacific participated in a lighting strategies-focused Utility Conservation Benchmark Session at the Railroad Environmental Conference organized by the Association of American Railroads.

  • We launched a Summer Energy Savings Contest with more than 33,000 field employees. The competition asked employees to submit their actions and ideas for reducing energy consumption. Submissions ranged from turning off lights and adjusting thermostats to shutting down idle equipment.
  • We established a 2015 capital strategy to replace more than 60 air compressor systems.
  • To improve upon its Silver LEED-EB-certified headquarters' building in Omaha, Nebraska, we updated the automated building control system, adjusted floor lighting schedules and installed LED lights in multiple applications.
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Energy Consumption*201220132014
Diesel1,103.8 gallons1,103.5 gallons1,171.2 gallons
Gasoline12.1 gallons12.9 gallons12.7 gallons
Other fuel8.6 gallons13.8 gallons13.6 gallons
Electricity603.5 kilowatt hours652.9 kilowatt hours627.1 kilowatt hours
Natural gas1,000.8 standard cubic feet761.8 standard cubic feet720.4 standard cubic feet

* estimated in millions

Sustainability Report 2015 - Environment Waste Management - Employee Ideas

Waste Management

As we work to improve our efficiencies as a company and minimize our environmental impacts, reducing and diverting waste are two key objectives. We estimate that we generated about 1.10 million tons of waste in 2014. We diverted from landfills more than 840,000 tons of waste, an estimated 77 percent of our waste.

Our employees are a powerful resource for improving our waste management and environmental citizenship. In 2008, we formally began encouraging employees to suggest environmental sustainability tips and ideas. So far, we have received more than 3,200 ideas from more than 1,800 people. More than 40 percent of these suggestions led to changes in our programs and processes.

Our Efforts

  • Reducing Hazardous Waste. We decreased the number of federal large quantity hazardous waste generator sites from 35 in 1991 to two in 2015. The reduction resulted from a concerted effort to replace hazardous solvents with nonhazardous ones. We also implemented a battery recycling program and began using nonhazardous water-based paints.
  • Increasing Recycling. We have expanded our recycling of cardboard, paper, plastics and other municipal solid waste. By the end of 2014, recycling was in place at more than 300 locations in 150-plus cities, including virtually every major location and a significant number of smaller locations.
  • Making Smart Choices. We have strengthened our process to ensure compliance with waste disposal regulatory requirements by keeping employees current on waste characterization changes.


Union Pacific recycles electronics that have reached the end of their useful life, commonly known as e-waste. The company recycled or distributed more than 270,000 pounds of electronic equipment and more than 1.2 million pounds of signal batteries.

Fuel And Oil

We recycled more than 5.3 million gallons of oil and fuel. Our equipment and maintenance processes capture used oil and fuel at our facilities for recycling. In addition, drip pans and other collection systems are placed under engines to catch spills, separators extract engine oil from wastewater and fuel nozzles shut off automatically to prevent overflow.

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In accordance with our Environmental Policy, Union Pacific strives to be a responsible steward of America's resources, including water. We estimate that we used 2.085 billion gallons of water in 2014. For the first time, the company also participated in CDP's water questionnaire, outlining efforts to responsibly manage water.

The company's role in water management stretches back to our beginnings, as we frequently were the first land developer across the western United States. To this day, Union Pacific is responsible for providing safe drinking water to the public in a handful of locations. Water is challenging to manage, as we have thousands of water utility accounts across our 32,000-mile network. In addition, older structures can make it challenging to reduce our energy and water usage. We continue efforts to conserve and reduce water use at our facilities.

Protecting groundwater also is important. We prepared and implemented Spill Prevention Control and Countermeasure (SPCC) plans at more than 130 Union Pacific facilities. We also operate and maintain 89 wastewater treatment facilities that capture wastewater created during equipment washing, locomotive fueling and maintenance, intermodal crane and truck maintenance, track and roadway equipment shop maintenance and stormwater accumulation at shop facilities. To ensure it meets acceptable cleanliness levels, captured wastewater undergoes treatment that requires stringent compliance with governmental regulations and wastewater discharge permits.

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Union Pacific and the Land

Union Pacific balances its commitment to transporting goods efficiently with other considerations, including safety, as well as its impact on communities, wildlife and the environment. Ensuring the preservation and resiliency of the land on which we operate helps us as a business and is a priority for the company.

Rail operations can contribute to land and water contamination. Union Pacific actively works to prevent contamination by employing best practices in operations, overseeing lease tenants and proactively working with customers. We also restore land contaminated by prior rail operations. In some cases, Union Pacific works with regulators to go beyond the minimum remediation requirements to further protect the land and waterways.

Among other efforts, we focus on working with tenants to improve environmental conditions of lease sites, addressing land impacts as part of our preparedness initiatives and incorporating soil reuse criteria for construction projects.

Rail-owned lands can provide value as community resources, and Union Pacific has helped transition properties for community enjoyment.

Occasionally, Union Pacific donates surplus land to cities, counties, states and non-profit organizations. Often, these lands extend or connect trails in urban and rural areas. Donations in the last two years include land in Missouri and Iowa.

The U.S. government's award of land grants to the company as part of building the transcontinental railroad also established Union Pacific as a manager of the land. With ownership of about 1 million acres, Union Pacific plays an active role in managing land and creating environmental and social value. Other activities that benefit the land include:

  • Recreational projects: Union Pacific donations and site improvements have opened outdoor venues for public use across the west. For instance, Union Pacific's efforts to create the 72-mile Trail of the Coeur d'Alene in Idaho's Panhandle earned a Phoenix Award for excellence in brownfield redevelopment. Residents in Utah, Wyoming, Colorado and other locations benefit from additional recreational projects.
  • Protection of ecological and endangered species: Union Pacific assesses habitats and establishes effective plans for preserving them. For instance, our Habitat Conservation Plan establishes operational processes and protects the desert tortoise, an endangered species in southern Nevada. In the Southwest, the company has worked to protect the endangered willow flycatcher. Since 1959, Union Pacific has maintained 30 miles of trees that serve as a windbreak from blowing sand in the Mojave Desert. Union Pacific also actively employs phytoremediation, the use of plants to remove contamination from the ground. The company also manages wetlands areas.
  • Commercial and residential redevelopment: Union Pacific operations frequently are at the heart of redevelopment opportunities. Union Pacific has transitioned holdings to bring new life to cities. Whether through transferring iconic depots or developing land into sports, entertainment or other venues, Union Pacific helps improve skylines and build new neighborhoods. Examples of Union Pacific's ongoing connection to redevelopment are found in Denver; Dallas; Houston; Omaha, Nebraska; Sacramento, California; Salt Lake City and San Jose, California.
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Sustainability Report 2015 - Main - Compliance


Union Pacific is committed to following applicable laws and regulations in all areas of our operations. From time to time, we are involved in legal proceedings, claims and litigation that occur in connection with our business. For example, we received notices from the U.S. Environmental Protection Agency and state environmental agencies alleging that we are or may be liable under federal or state environmental laws for remediation costs at various sites throughout the United States, including sites on the Superfund National Priorities List or state superfund lists. We cannot predict the ultimate impact of these proceedings and suits because of the number of potentially responsible parties involved, the degree of contamination by various wastes, the scarcity and quality of volumetric data related to many of the sites, and the speculative nature of remediation costs. Where we are found in violation of specific rules or regulations, we seek remedy through the appropriate channels.