May 22, 2019 Cynthia C. Earhart Chief Financial Officer NORFOLK SOUTHERN CORP Three Commercial Place Norfolk, Virginia 23510 Re: NORFOLK SOUTHERN CORP Form 10-K for the Year Ended December 31, 2018 Filed February 8, 2019 File No. 001-08339 Dear Ms. Earhart: We have completed our review of your filings. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Transportation and Leisure cc: Sheryl Winter