Canadian National Railway proposed to expand its network access in Kansas City and St. Louis as a condition of the $71.5 billion merger between Union Pacific and Norfolk Southern.

The Canadian railway operator said its proposals are pursuant to a binding memorandum of understanding between it and Union Pacific, which created a framework for the company to expand access to remedy what it described as competitive harms from the pending merger.

The proposals were filed with the Surface Transportation Board, a U.S. railroad regulator, and describes the conditions CN Rail expects to seek as part of the merger.

Those conditions include new and improved access to East St. Louis, Ill., along with St. Louis and Kansas City, including rights between the two metropolitan areas. CN Rail also said it will propose preserving competitive options in Illinois and Iowa in areas where the merger would reduce the number of Class I rail options.

"CN believes these conditions would address competitive harms from the proposed transaction, strengthen competition across the Midwest and provide shippers with additional service and routing options," the company said.

CN had disclosed the proposed deal with Union Pacific in July, promising to drop its opposition to the merger. Its final requests for conditions are due Nov. 18.

Other railroad companies continue to oppose the merger, including BNSF Railway, which last month asked regulators to reject the deal, which it described as anticompetitive.