Better re-read the NMB Regs. Companies (carriers) cannot petition for single carrier status. It is a representational issue between labor groups.
NOT!
NMB Regulations
19.1 Merger
Merger is a consolidation, merger, purchase, lease, operating contract, acquisition of control, or similar transaction of two or more business entities.
19.3 Notice to NMB
A Carrier should notify the NMB, in writing when any of the transactions described in Section 19.1 occur, or of:
1) an intent to merge, at the same time it files with the Surface Transportation Board (STB) or the Department of Transportation
(DOT); and
2) a completed merger including the date of the merger and the Carriers (or business entities) involved. Notices must comply with the service requirements of Section 1.2.
19.4 Initiation of Procedure for Determination of a Single Transportation System
Any organization or individual may file an application, supported by evidence of representation or a showing of interest (See Section 19.601-2), seeking a NMB determination that a single transportation system exists.
19.5 Merger Investigations
After an application is filed, the NMB will conduct a pre-docket investigation to determine whether a single transportation system exists. The investigation may take any form appropriate to the determination.
19.501 Factors Indicating a Single Transportation System
The following are some indicia of a single transportation system:
(1) published combined schedules or combined routes;
(2) standardized uniforms;
(3) common marketing, markings or insignia;
(4) integrated essential operations such as scheduling or dispatching;
(5) centralized labor and personnel operations;
(6) combined or common management, corporate officers, and board of directors;
(7) combined workforce; and,
(8) common or overlapping ownership.
From "The Railway Labor Act"
By Douglas L. Leslie
Chapter 2
B. Carrier Petitions for Investigation
Unlike in all other representations disputes, which must be initiated by a labor organization, a carrier facing a relevant change in corporate structure may, according to the NMB Merger Procedures, petition for investigation of a merger representations dispute. A carrier files with the Board at the time it applies to the Department of Transportations (DOT) or the ICC for approval of a transaction. The carrier must state when it intends to operate as a single transportations system or as separate systems. If the carrier does not intend to effect an operational merger immediately after obtaining DOT or ICC approval, but determines to do so at some later time, the carrier must again invoke the NMB's services at that later time, prior to the operations merger.