When Trains, Horns, and Federal Law Collide: A 2026 Guide for Plymouth, Michigan and Other City Officials

For Plymouth‑area residents, rail lines are part of the community's identity, but so are late‑night horns and long delays at blocked crossings. From my office window, I watch the trains pass and hear the horns, just as residents do. Based on work as counsel and senior executive for railroads involved in federally funded corridor and crossing projects, I have seen how quickly local concerns run into federal law and funding realities, and this guide is meant to unpack that for city officials. Plymouth happens to be the example here (because that is where I am), but it stands in for any community that is trying in good faith to solve rail‑related problems with limited local tools and a railroad that can be difficult to move.

As an attorney who has represented railroads and worked with communities on crossing projects, diagnostic reviews, negotiations with railroads, engineering and feasibility studies, and federal and state funding for grade‑separation projects, I have seen how uniquely complex these matters can be from the municipal side. There are no easy fixes.

This post outlines three practical questions for Plymouth and other Michigan cities: what they can do about train horns, what they cannot do about blocked crossings, and how they might leverage new federal and state programs to physically redesign their most problematic crossings.

Plymouth's rail reality

Plymouth hosts a major CSX yard with multiple public crossings in a compact downtown, which produces frequent train movements, horn noise, and recurring congestion when crossings are blocked. Over the last decade, residents have pressed the City to reduce horn noise through quiet zones and to address long blockages that impede everyday travel and emergency response.

Key local history includes:

• The City studied establishing quiet zones at several public crossings after organized resident advocacy, including the Plymouth Quiet Zones initiative.

• After cost and risk analysis, the City Commission declined to implement quiet zones, citing high capital costs, potential increased liability, and questions about whether benefits justified the expenditure.

• Complaints about blocked crossings and mobility constraints have persisted, especially as construction and traffic patterns have left residents with few alternatives when trains stop across key arterials.

Against that backdrop, any policy discussion must square local expectations with the hard edges of federal preemption and the practicalities of large-scale rail-infrastructure funding.

Quiet zones

Under the Federal Railroad Administration's Train Horn Rule, locomotive engineers must sound the horn at public highway-rail crossings, subject to detailed timing and pattern requirements. A quiet zone is a segment of railroad track, at least one‑half mile in length, where routine train horn sounding at public grade crossings is prohibited and safety is maintained through alternative measures such as interconnected gates, medians, and fencing.

In theory, this fix sounds simple. In practice, it requires complex engineering, detailed safety reviews, and a careful legal negotiation process with a party that will not accept any increase in potential liability and may prefer that the projects not move forward at all. For Plymouth or any Michigan city, several legal and practical points matter:

• Authority and process. Only a public authority responsible for the roadway can establish a quiet zone, through either a direct designation if risk scores are low enough or an FRA process showing equivalent or better safety using supplemental or alternative safety measures.

• Typical engineering measures. Quiet zones often require median barriers, four-quadrant gates, channelization devices, or closure of certain crossings to prevent drivers from going around gates, all of which raise project cost and design-review complexity.

• Michigan's role. MDOT inspects and regulates highway-rail crossings and publishes guidelines for crossing design and traffic control devices, but it does not create quiet zones on behalf of municipalities; local governments must sponsor and fund them.

• Risk and liability. While FRA's framework is designed to maintain or improve safety, shifting from horn-based warnings to physical measures can change the litigation landscape if an incident occurs at a quiet-zone crossing that is alleged to be under-protected or poorly maintained.

A quiet zone is evaluated as a system: risk calculations, diagnostic reviews, and design decisions all look at how a string of crossings works together, how traffic diverts from one crossing to another, and whether the overall safety level meets or exceeds the federal standard. Tackling one crossing at a time can lead to duplicative design work, uneven protection from one intersection to the next, and higher per‑crossing costs, while still failing to achieve a legally defensible quiet zone. A corridor plan, by contrast, allows the city(ies), the railroad, and their engineers to coordinate upgrades, share costs and responsibilities, and document a consistent safety strategy across all affected crossings, which matters both for funding and for managing long‑term liability.

Blocked crossings and preemption

Blocked crossings raise a different set of issues. Residents experience delays, school buses and emergency vehicles can be trapped, and downtown circulation can grind to a halt, but attempts to legislate those blockages at the local level have largely failed in court.

Two federal statutes drive that result:

• Interstate Commerce Commission Termination Act. ICCTA gives the Surface Transportation Board exclusive jurisdiction over railroad operations and broadly preempts state and local regulation that manages or governs rail transportation, including operations that cause blockages.

• Federal Railroad Safety Act. FRSA establishes a national framework for railroad safety and preempts state and local laws covering the subject matter of federal regulations, with a narrow savings clause for essentially local safety hazards that are not adequately addressed at the federal level.

In this area, Plymouth is not just a stakeholder; it is a community that, in good faith, tried to use the tools available under state law to address blocked crossings and found itself at the center of a leading federal preemption case:

• CSX Transportation, Inc. v. City of Plymouth, 92 F. Supp. 2d 643 (E.D. Mich. 2000), aff'd, 283 F.3d 812 (6th Cir. 2002). CSX challenged enforcement of a Michigan anti-blocking statute and related local enforcement in Plymouth, arguing that the five-minute blocking limit was preempted and burdened interstate commerce. The Eastern District of Michigan held that the statute was preempted by both FRSA and ICCTA, and the Sixth Circuit affirmed, concluding that anti-blocking time-limit laws impermissibly intrude into federally regulated railroad operations.

The Plymouth case is not the only decision to reach this conclusion, and the consistent message from these cases and federal policy documents is that anti-blocking ordinances and similar local regulations are high-risk, low-reward tools that are unlikely to withstand judicial review. In practical terms, this significantly ties the hands of local officials who are looking for direct regulatory fixes to blocked‑crossing problems and pushes the real solutions into the realm of infrastructure and funding.

New funding options

The legal system's answer to blocked crossings is increasingly to build a way out, not fine the railroad. For Plymouth, that means paying close attention to several relatively new funding programs.

Federal Railroad Crossing Elimination grants

The 2021 Infrastructure Investment and Jobs Act established the Railroad Crossing Elimination Grant Program, administered by FRA, to fund highway-rail grade-crossing projects that enhance safety and mobility.

Key features include:

• RCE funds grade separations, track relocation, crossing closures and consolidations, and installation of protective devices and technology to improve safety and traffic flow.

• The program has awarded more than 1.1 billion dollars in recent rounds to projects in dozens of states, making it the largest dedicated federal investment in grade-crossing safety to date.

• A significant portion of each funding round is set aside for rural and tribal projects, while a planning set-aside supports early-stage studies of potential grade separations and corridor-wide solutions.

For cities like Plymouth, RCE is a potential vehicle to fund a bridge or underpass at a chronically blocked crossing, or to close and consolidate crossings as part of a corridor plan that also supports quiet‑zone eligibility. However, the sheer cost, high local match requirements, property impacts, traffic detours, and years of construction inherent in a multi‑year grade‑separation project can make even a fully awarded grant feel like a heavy lift for the community.

The new federal “Corridor ID” mindset. 

FRA has long evaluated quiet zones as corridors of crossings, not isolated intersections. Risk scores, diagnostic reviews, and design decisions all look at how a string of crossings operates as a system along a defined segment of track. In the wake of the 2021 federal infrastructure law, FRA has gone a step further by creating a formal Corridor Identification and Development (“Corridor ID”) program for intercity passenger rail, which uses designated corridors as the basic unit for planning and future funding decisions. Recent policy updates in 2025 and 2026 have sharpened that structure by breaking corridor planning into staged “core” and “comprehensive” tracks and by explicitly treating Corridor ID as the on‑ramp to larger capital programs. For cities like Plymouth, the practical point is that federal law and policy now assume rail issues will be addressed at the corridor level, whether the goal is to silence horns through a quiet zone, unclog a set of blocked crossings, or position a community for future passenger‑rail investments. Understanding how this process works can be a real advantage for communities that are ready to take advantage of these changes.

Other federal and state programs

Beyond RCE, communities can also look to broader discretionary transportation grants and state matching programs.

• RAISE and similar discretionary grants can fund road-rail grade separations, complete-streets projects involving rail corridors, and intermodal improvements where rail and local traffic interact.

• FRA administers additional rail-improvement grants under IIJA that sometimes include grade-crossing components as part of corridor upgrades, capacity improvements, or safety projects.

• Michigan has created a state rail grade-separation initiative within MDOT and also offers the Michigan Rail Enhancement Program, which can help support freight-rail and crossing infrastructure and may complement federal applications.Because most federal grants require non-federal match funding, Michigan programs and local capital contributions can be combined to build a viable funding stack.

What city officials should do now

For city managers, planners, and attorneys in communities like Plymouth, the most productive path is to stop treating rail problems as isolated local annoyances and start treating them as corridor issues with legal, engineering, and funding dimensions. Plymouth’s experience shows that direct regulation of blocked crossings is a poor use of local political capital, because anti‑blocking ordinances are very likely to be preempted under FRSA and ICCTA. Instead, cities should focus on federally authorized tools such as quiet zones, diagnostic crossing reviews, FRA‑approved safety measures, and long‑range grade‑separation planning.

That same corridor mindset should shape how Plymouth engages with MDOT. The CSX line through downtown Plymouth is not currently an FRA‑designated Corridor ID route, but from MDOT’s perspective it sits within the geography of the proposed Coast‑to‑Coast passenger corridor linking Grand Rapids, Lansing, Ann Arbor, and Detroit. That means Plymouth has an opportunity now, not by trying to regulate the railroad more aggressively, but by making itself visible and useful to the state’s planning process as it “IDs” the corridor.

Several practical steps follow.

• Accept the preemption reality. Anti‑blocking time‑limit ordinances are unlikely to survive challenge, so the better strategy is to work within federal law rather than against it.

• Use federally authorized pathways. Quiet zones and related crossing‑safety improvements are expressly contemplated by FRA regulations and offer a lawful route to reducing horn noise.

• Plan for grade separation. Identify the one or two crossings where a bridge or underpass would most improve safety, mobility, and emergency access, and build a data‑driven record using traffic counts, blockage duration, crash and near‑miss information, and emergency‑response impacts.

• Coordinate regionally. Multi‑jurisdictional and corridor‑wide projects are often more competitive for discretionary funding than single‑crossing applications.

• Support the Coast‑to‑Coast study. Plymouth can adopt a formal resolution supporting MDOT’s work on the Holland–Grand Rapids–Lansing–Ann Arbor–Detroit corridor and ask that the CSX alignment through Plymouth remain part of the analysis.

• Feed MDOT useful local data. Land‑use plans, redevelopment concepts, traffic and crossing data, employer and institutional support, and station‑area possibilities all help MDOT show that the corridor serves real transportation and economic needs.

• Align local planning with the corridor concept. Street design, zoning, right‑of‑way preservation, and crossing improvements near the rail line should be documented in a way that supports future passenger‑rail or corridor‑level investment.

• Engage counsel early. Railroad projects sit at the intersection of federal preemption, transportation regulation, municipal law, engineering review, and grant conditions, so early legal input can prevent expensive mistakes.

If Plymouth and neighboring communities do that groundwork, they improve the odds that this line will be viewed not simply as a freight obstacle but as part of a corridor with broader state and federal significance. That matters because if FRA ultimately designates a Coast‑to‑Coast corridor that uses the Plymouth line and MDOT advances it through the Corridor ID process, Plymouth’s most expensive rail‑related projects may become substantially easier to fund as part of a larger package, with MDOT funding and other non‑federal dollars helping to satisfy federal match requirements and potentially saving Plymouth and neighboring communities millions in local costs:

• Corridor ID brings a formal planning pathway and federal planning support, so early development work such as service planning, environmental review, and conceptual engineering would be carried by MDOT and corridor sponsors rather than resting entirely on the City.

• A designated corridor is in a stronger position for later capital funding through larger federal rail programs, which can include grade separations, signal work, and capacity improvements along the route.

• Corridor‑wide projects generally produce better benefit‑cost numbers than stand‑alone local applications because they capture broader mobility, safety, and economic gains across multiple communities. In practical terms, that can reduce the local share Plymouth might otherwise have to carry for a bridge, underpass, crossing consolidation, or related improvements.

In work on railroad matters across multiple communities, corridor‑based packages that combined bridges, closures, siding improvements, or double‑track work consistently performed better in grant competitions than single‑crossing requests. For Plymouth, the lesson is straightforward. The City is more likely to make progress by positioning itself as a ready partner in a larger corridor strategy than by pursuing one‑off fixes in isolation.

For Oxbridge Legal Services, these issues are not abstract questions of federal preemption. They are exactly the kind of legally and operationally complex infrastructure problems that require coordinated advice at the front end. With experience representing railroads and working alongside communities on quiet zones, diagnostic reviews, corridor planning, and grade‑separation strategy, Oxbridge helps local governments move from reactive complaint management to proactive corridor planning that aligns legal risk, engineering realities, and long‑term community goals.