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                             November 12, 2021

       Jennifer L. Hamann
       Chief Financial Officer
       Union Pacific Corporation
       1400 Douglas Street
       Omaha, Nebraska 68179

                                                        Re: Union Pacific
Corporation
                                                            Form 10-K for
Fiscal Year Ended December 31, 2020
                                                            Response Dated
October 15, 2021
                                                            File No. 001-06075

       Dear Ms. Hamann:

              We have reviewed your October 15, 2021 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 17, 2021 letter.

       Response Letter Dated October 15, 2021

       Form 10-K for Fiscal Year Ended December 31, 2020

   1.                                                   Please provide us with
quantification of amounts incurred as support for the statement
                                                        made in response to
comment 1 that investments made to harden portions of your rail
                                                        network identified as
more susceptible to climate-related damage have not been material
                                                        to the periods covered
by your 2020 Form 10-K.
   2.                                                   Your response to prior
comment 2 regarding reputational risks resulting from operations
                                                        that produce material
greenhouse gas emissions appears to focus on emissions from the
                                                        railroad industry
compared to other types of ground transportation services. Please revise
                                                        to provide disclosure
explaining how your reputation or brand could be negatively
                                                        impacted as a result of
emissions of greenhouse gasses from your own operations, such as
                                                        diesel exhaust.
 Jennifer L. Hamann
Union Pacific Corporation
November 12, 2021
Page 2
3.       We note your response to comment 3 and the reference to disclosure in
your 2019 Form
         10-K. We also note the reference to weather-related events, such as
wildfire and heavy
         rain, during the current year in your response to prior comment 1. We
partially reissue
         our prior comment as it does not appear that you have provided
quantification of material
         weather-related damages to your property or operations as a
significant physical effect of
         climate change.
4.       In your response to comment 3, you state that agricultural product
shipments have been
         impacted by weather-related challenges. Please tell us how your
disclosure considers
         climate change as a business risk due to its potential effect on your
customers in the
         agricultural industry.
5.       We note from you response to comment 3 that you have experienced an
increase in
         insurance premiums, however, these increases did not have a material
effect on your
         business, financial condition, and results of operations. Provide us
with additional detail
         to support this statement, including quantification. In addition, tell
us how you evaluated
         weather-related impacts on the availability of insurance.
       You may contact Diane Fritz (Staff Accountant) at (202) 551-3331 or Brad
Skinner
(Office Chief) at (202) 551-3489 if you have questions.



FirstName LastNameJennifer L. Hamann                           Sincerely,
Comapany NameUnion Pacific Corporation
                                                               Division of
Corporation Finance
November 12, 2021 Page 2                                       Office of Energy
& Transportation
FirstName LastName