RAILROAD SAFETY

Quiet Zone Analyses 

and Inspections Could 

Be Improved

Report to Congressional Addressees

October 2017

GAO-18-97

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-97, a report to 

congressional addressees

October 2017

RAILROAD SAFETY

Quiet Zone Analyses and Inspections Could Be 

Improved

What GAO Found

GAO found that the benefits of quiet zones—–i.e., highway-rail at-grade 

crossings (grade crossings) where train horns are not sounded—have not been 

quantified and that the costs to establish quiet zones vary. The Federal Railroad 

Administration’s (FRA) train horn regulations allow public authorities (e.g., cities 

or towns) the opportunity to establish quiet zones if they install safety measures 

that reduce risks associated with the absence of the train horn (see fig.). While 

GAO did not identify any research that has quantified the benefits of quiet zones, 

most stakeholders GAO interviewed said that these quiet zones provide benefits 

to communities, such as reducing noise or increasing economic development. 

According to FRA guidance, the factors that affect the costs to establish quiet 

zones can vary based on the number of grade crossings and types of safety 

measures used. Public authorities, which typically incur the costs and receive the 

benefits of quiet zones, must therefore decide whether the benefits of quiet 

zones exceed the costs.

Examples of the Federal Railroad Administration’s Approved Quiet Zone Safety Measures

To evaluate the effectiveness of its train horn regulations, FRA has analyzed 

data on grade crossings in quiet zones and is transitioning to a formal process 

for inspecting quiet zones. 

• Analyses: FRA’s analyses showed grade crossings in quiet zones were

generally as safe as they were when train horns were sounded. However,

these analyses did not control for changes to grade crossings’ characteristics

over time—–e.g., train speeds or frequency. Such changes may decrease

the analyses’ reliability. A revised methodology that accounts for these

changes could provide FRA with better information on the long-term effects

of the train horn regulations, including the safety of quiet zones.

• Inspections: Recognizing the need for additional oversight, FRA has taken

steps to formalize its process for inspecting quiet zones. FRA has primarily

relied on public authorities to oversee quiet zones and ensure compliance

with the train horn regulations, in addition to informal inspections by FRA’s

Grade Crossing Managers. In September 2017, FRA began conducting

formal inspections of quiet zones using Grade Crossing Inspectors. However,

FRA has not developed guidance for how inspections are to be conducted,

including how frequently inspections are to be performed or what should be

examined. Without guidance, FRA cannot ensure that inspections are being

conducted consistently across FRA’s eight regions. View GAO-18-97. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov. 

Why GAO Did This Study

Accidents at grade crossings are a 

major source of fatalities in the railroad 

industry. FRA—the federal agency 

responsible for providing regulatory 

oversight of grade-crossing safety—–

issued regulations on the use of train 

horns in 2005. Railroads generally 

support sounding the horn, whereas, 

communities often support quiet zones 

to reduce noise. 

Congress included a provision in

statute for GAO to examine FRA’s train 

horn regulations, including those on 

quiet zones. Among other things, this 

report: (1) describes benefits and costs

of quiet zones, and (2) examines how 

FRA evaluates the effectiveness of its 

train horn regulations. GAO analyzed

FRA’s documentation on quiet zones,

including FRA’s train horn regulations 

and 2011 and 2013 studies on quiet 

zone safety; reviewed literature; and 

interviewed FRA program officials in 

headquarters, Grade Crossing 

Managers in FRA’s 8 regions, and a 

nongeneralizable sample of another 32 

stakeholders from 6 states, railroads, 

public authorities, and private industry 

consulting firms. State and public 

authorities were selected based on the

number of quiet zones, geographic 

diversity, and FRA’s recommendations. 

What GAO Recommends

GAO recommends that FRA: (1) revise 

its methodology for analyzing the 

safety of quiet zones, and (2) develop

guidance on conducting quiet zone 

inspections. The Department of 

Transportation partially concurred with 

the first recommendation, saying it 

would consider it, and fully concurred 

with the second. GAO continues to 

believe changes to the methodology 

are needed, as discussed in the report.
Page i GAO-18-97 Railroad Safety

Letter 1

Background 5

Benefits of Quiet Zones Have Not Been Quantified, and Costs 

Depend on Many Factors 12

Selected Public Authorities and Other Stakeholders Reported 

Several Challenges in Establishing Quiet Zones and Suggested 

Potential Improvements 17

FRA Has Conducted Analyses of Safety in Quiet Zones and Is 

Formalizing Quiet Zone Inspections, but Limitations Exist 22

Conclusions 29

Recommendations for Executive Action 29

Agency Comments and Our Evaluation 30

Appendix I Objectives, Scope, and Methodology 32

Appendix II Comments from the Department of Transportation 41

Appendix III List of Organizations Contacted by GAO 43

Appendix IV GAO Contact and Staff Acknowledgments 45

Tables

Table 1: States and Public Authorities Included in GAO’s Review 34

Table 2: Categories of Quiet Zone Challenges and Categories of 

Improvements Suggested by Stakeholders and Definitions 38

Table 3: List of Organizations Contacted by GAO 43

Figures

Figure 1: New Quiet Zones Established in the United States from 

June 2005 to June 2017 7

Figure 2: Process Public Authorities Follow to Establish Quiet 

Zones 9

Contents
Page ii GAO-18-97 Railroad Safety

Abbreviations

ASM alternative safety measure 

CCM ccmMercury 

GCIS Grade Crossing Inventory System 

GCM Grade Crossing Manager 

FHWA Federal Highway Administration 

FRA Federal Railroad Administration 

NOI Notice of Intent

OMB Office of Management and Budget

RAIRS Railroad Accident/Incident Reporting System 

RFIA Regulatory Evaluation and Regulatory Flexibility 

Assessment for Use of Locomotive Horns at Highway-Rail 

Grade Crossings Final Rule 

SSM supplemental safety measure

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Page 1 GAO-18-97 Railroad Safety

441 G St. N.W.

Washington, DC 20548

October 31, 2017 

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Ed Perlmutter

House of Representatives

Accidents where railroad tracks cross roads (termed “grade crossings”) 

are a major source of fatalities in the U.S. railroad industry.1 According to 

data from the Federal Railroad Administration (FRA)—the federal agency 

that oversees rail safety, including the safety of grade crossings—in 2016 

there were more than 2,000 accidents at grade crossings, resulting in 264 

fatalities, or about 36 percent of all railroad fatalities.

To prevent accidents at grade crossings, railroads have historically 

sounded their horns to warn motorists of oncoming trains. However, 

according to FRA, since the 1970s, many cities, counties, and towns 

around the nation enacted whistle bans (i.e., local ordinances which 

prohibit or restrict the use of train horns or whistles at grade crossings).

2

The whistle bans were allowed due in part to community complaints about 

1

According to FRA guidance, grade crossing accidents can also be referred to as grade 

crossing incidents, or grade crossing collisions. To be recorded as a grade crossing 

accident, an accident must meet three conditions: (1) involve on-track equipment, (2) 

involve a highway user, and (3) the accident occurs at a designated grade crossing. 

2

For example, in 1984 the state of Florida authorized local communities to ban the 

sounding of horns by intrastate railroads if the grade crossings were equipped with 

flashing lights and gates. This ban primarily affected the Florida East Coast Railway 

Company.

Letter
Page 2 GAO-18-97 Railroad Safety

the negative effects of the train horn noise on resident’s quality of life. 

While whistle bans may have reduced noise, in 1990 FRA conducted an 

analysis on Florida’s whistle bans that showed that they led to a 195 

percent increase in accidents at grade crossings during nighttime hours.

Partially as a result of FRA’s analysis and the spike in accidents 

associated with selected whistle bans, in 1994 FRA was required in 

statute to issue train horn regulations governing the sounding of train 

horns at all public grade crossings.3 The statute also provided FRA 

authority to make exceptions. In August 2006, FRA issued its final rule on 

the use of locomotive horns at highway-rail-grade crossings.4 The rule 

provided states and public authorities5 with an opportunity to establish 

“quiet zones,” where train horns are not routinely sounded as trains 

approach grade crossings.6 However, certain conditions must be met to

mitigate the increased risks resulting from the absence of the train horn. 

While grade-crossing accidents have remained relatively constant in 

recent years, federal and private-sector railroad officials remain 

concerned about grade crossings’ safety, including whether grade 

crossings in quiet zones are as safe as grade crossings where the train 

horn is sounded. These concerns are often in conflict with public 

authorities who want to establish quiet zones to reduce noise.

The Fixing America’s Surface Transportation Act included a provision for 

GAO to review FRA’s final rule.7 This report discusses: (1) what is known 

3

Pub. L. No. 103-440, § 302(a)(1994). Public-highway-rail-grade crossings are locations 

where a public highway, road, or street crosses one or more railroad tracks at-grade. 

Private-highway-rail-grade crossings are highway-rail-grade crossings which are not a 

public-highway-rail grade crossing. 49 C.F.R. § 222.9. Throughout this report we will refer 

to public-highway-rail grade crossings as grade crossings, and specify when we are 

referring to private highway-rail-grade crossings.

4

The final rule was codified in parts 222 and 229 of Title 49, Code of Federal Regulations. 

An interim final rule was issued in December 2003. The final rule was initially issued in 

April 2005; however, after petitions for reconsideration were received a revised final rule 

was issued in August 2006. 71 Fed. Reg. 47614 (Aug. 17, 2006). Reference to the final 

rule is the revised final rule issued in August 2006. 

5

Public authority means the public entity responsible for traffic control or law enforcement 

at the public highway-rail-grade or pedestrian crossing. According to FRA officials, public 

authorities can include cities, towns, or counties.

6

A “quiet zone” is a section of rail line at least one-half mile in length that contains one or 

more consecutive public grade crossings at which train horns are not routinely sounded 

when approaching the grade crossings. 

7 Pub. L. No.114-94, § 11403(a) (2015).
Page 3 GAO-18-97 Railroad Safety

about the benefits and costs of quiet zones; (2) what challenges, if any, 

public authorities and others encounter in establishing quiet zones; and 

(3) how, if at all, FRA is evaluating the effectiveness of federal train horn 

regulations.

The scope of this work focused primarily on new quiet zones—that is, 

quiet zones that were established after FRA issued the train horn 

regulations in August 2006.8 For each of our objectives, we reviewed 

pertinent FRA regulations and documents; conducted a literature review 

of academic material on quiet zones;9 interviewed FRA program officials 

in headquarters and conducted in-depth interviews with a 

nongeneralizable sample of 40 stakeholders—including officials from 8 

freight railroads, 5 private industry consulting firms with experience 

helping public authorities establish quiet zones, 6 state agencies, 13 

public authorities that established quiet zones within these 6 states, and 

Grade Crossing Managers (GCM)10 in each of FRA’s 8 regions. We 

selected the states based on a number of factors including the number of 

quiet zones established since federal regulations were issued, the 

number of grade crossings within quiet zones, and geographic diversity.11

We selected the public authorities for interviews based on factors similar 

to the state selections, such as the number of new quiet zones, the 

number of grade crossings in new quiet zones, geographic diversity, and 

recommendations from FRA’s GCMs and FRA’s program officials. We 

asked each of these stakeholder groups a similar set of questions to 

8

The federal train horn regulations also included provisions for pre-rule quiet zones—

grade crossings at which state statutes or local ordinances restricted the routine sounding 

of train horns, or at which locomotive horns did not sound due to formal or informal 

agreements between the public authority and the railroad(s) prior to the train horn 

regulations. The train horn regulations excludes about 390 crossings in Chicago, Illinois 

(called the “Chicago Region Exemption”), which were governed by the Illinois Commerce 

Commission.

9

We conducted a literature review of pertinent studies in peer-reviewed journals, trade 

publications, and conferences, among others, published from January 1, 1996, through 

October 17, 2016.

10GCMs, officially known as Crossing and Trespasser Regional Managers, are 

responsible for, among other things, serving as subject matter experts on the federal train 

horn regulations and coordinating regional assistance to local public authorities regarding 

implementation of quiet zones. 

11Five of the states we selected had the highest number of new quiet zones—California, 

Colorado, Florida, Illinois, and Texas. We also conducted interviews in Maryland before 

we conducted other interviews to test our interview protocol. Maryland was selected for 

this purpose because the location allowed us to minimize the resources required.
Page 4 GAO-18-97 Railroad Safety

gather the individual’s views on each of our objectives; these views 

cannot be generalized to others. With respect to the freight railroads, we 

selected the seven largest freight railroads, in addition to the railroad 

involved with the Florida whistle ban. The private industry consultants 

were selected based on recommendations from FRA and other 

stakeholders we interviewed.

We also conducted additional work related to each of the objectives:

• To describe what is known about the benefits and costs of quiet 

zones, we reviewed FRA’s Regulatory Evaluation and Regulatory 

Flexibility Assessment (RFIA), which evaluated the economic impacts 

of federal train horn regulations, and a user guide prepared by FRA 

on how to establish quiet zones.12

• To identify what challenges public authorities and other stakeholders 

encounter in establishing quiet zones, we conducted a content 

analysis of interviews with stakeholders identified above. We also 

reviewed FRA’s Notice of Safety Inquiry—the agency’s retrospective 

review of the final rule—issued in March 2016.13

• To determine how FRA is evaluating the effectiveness of FRA’s train 

horn regulations in quiet zones, we reviewed FRA’s safety studies, 

published in 2011 and 2013, that compared the safety of grade 

crossings before and after the establishment of the quiet zone to 

determine whether safety was impacted. To assess the reliability of 

FRA’s studies, we drew on established guidelines for assessing 

research, our reports on evaluating research programs, and our 

internal expertise in research design. We also compared FRA’s 

approach to federal internal controls related to information and 

communication.14 In addition, we reviewed FRA policies and 

procedures to determine its’ oversight approach and then compared 

 12FRA, Regulatory Evaluation and Regulatory Flexibility Assessment for Use of 

Locomotive Horns at Highway-Rail Grade Crossings Final Rule (49 C.F.R. Parts 222 and 

229) (Washington, D.C.: July 21, 2003); and FRA, Federal Railroad Administration, 

Highway-Rail Crossing and Trespasser Programs Division, Guide to the Quiet Zone 

Establishment Process: An Information Guide (Washington, D.C.: September 2013). The 

RFIA analyzed the potential economic effects of requiring the train horn to be sounded at 

all public grade crossings and eliminating whistle bans. 

13See 81 Fed. Reg. 11734 (Mar. 7, 2016). 

14GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 5 GAO-18-97 Railroad Safety

this approach to federal internal control standards that would be 

applicable to the control environment.

Finally, in order to obtain information about quiet zones, we reviewed 

FRA’s data on quiet zones established from 2005 through 2017. To 

assess the reliability of these data, we examined FRA reports, analyzed 

the data to identify any outliers, and interviewed FRA program officials 

about how the data were collected and used. We determined that the 

data were sufficiently reliable for our purposes. See appendix I for more 

information on our scope and methodology and appendix III for a list of 

organizations we contacted.

We conducted this performance audit from July 2016 to October 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The United States railroad system consists of a vast network of 

operations that includes more than 780 railroads operating across 

220,000 miles of track—including about 212,000 grade crossings. Both 

freight and passenger railroads operate across the system. The freight 

railroad industry is dominated by the seven largest railroads, referred to 

as class I railroads, whereas passenger rail service includes Amtrak and 

29 commuter railroads.15

FRA is responsible for providing regulatory oversight of the safety of both 

freight and passenger railroads. To accomplish this oversight, FRA issues 

and enforces numerous safety regulations, including requirements 

governing track, signal and train control systems, grade crossing warning 

systems, and railroad-operating practices. FRA monitors railroads’

compliance with federal safety regulations through routine and special 

 15The freight railroad industry is divided into three classes based on certain thresholds of 

annual operating revenues, as determined by the Surface Transportation Board. For 2016, 

this revenue threshold was at least $447.6 million for class I railroads, at least $35.8 

million for class II railroads, and less than $35.8 million for class III railroads.

Background
Page 6 GAO-18-97 Railroad Safety

emphasis inspections on railroads’ systems.16 FRA’s inspectors generally 

specialize in one of five areas. These inspection areas are called 

disciplines and include: (1) operating practices, (2) track, (3) hazardous 

materials, (4) signal and train control, and (5) motive power and 

equipment.

FRA also has specific responsibilities related to the safety of grade 

crossings, including issuing regulations regarding the use of train horns at 

grade crossings. FRA issued regulations in August 2006, after FRA’s 

analysis illustrated the dangers of whistle bans. Federal regulations 

require that train horns be sounded in advance of all public grade 

crossings.17 However, the regulations also provide an opportunity for 

public authorities to reduce the effects of noise associated with the train 

horn by establishing quiet zones. While railroads are directed to cease 

the routine sounding of the train horn at-grade crossings within quiet 

zones, the final rule states that train horns may still be sounded in 

emergency situations and to comply with other federal regulations and 

railroad operating rules.

As of June 2017, there were 570 new quiet zones located across 42 

states (see fig. 1).

 16FRA’s inspection approach focuses on direct observations of train components, related 

equipment, and railroad property, as well as operating practices to determine whether they 

meet federal safety standards. 17Train engineers are generally required to sound the 

horns at least 15 seconds, and no more than 20 seconds, in advance of all grade 

crossings. Train horns must be sounded in a standardized pattern of 2 long, 1 short and 1 

long blast, with the volume ranging from 96 decibels to 110 decibels.

17Train engineers are generally required to sound the horns at least 15 seconds, and no 

more than 20 seconds, in advance of all grade crossings. Train horns must be sounded in 

a standardized pattern of 2 long, 1 short and 1 long blast, with the volume ranging from 96 

decibels to 110 decibels.
Page 7 GAO-18-97 Railroad Safety

Figure 1: New Quiet Zones Established in the United States from June 2005 to June 2017

Public authorities must follow a number of steps and work with federal 

and state agencies, as well as railroads to establish quiet zones (see fig. 

2). At a minimum, each grade crossing within a quiet zone must include 

active warning devices—these include flashing lights, gates, constant 

warning time devices, and power out indicators.18 As shown in step 3

(fig.2), public authorities must select safety measures—either 

supplemental safety measures (SSM) or alternative safety measures 

 18Constant warning time is a railroad system that uses a train’s approach speed to 

determine when it will reach a grade crossing, and then start the crossing gate cycle a 

specified time before the train reaches the crossing. According to the final rule, constant 

warning time devices are required if reasonably practical. A power out indicator provides 

notification to train crews that there is no commercial electrical power at a grade crossing. 
Page 8 GAO-18-97 Railroad Safety

(ASM)—for grade crossings, measures that mitigate the increased risks 

of not sounding the train horn.19 SSMs—such as eliminating a grade 

crossing, installing traffic channelization devices20 extending 100 feet 

from the crossing gates, or installing four quadrant gates—are FRA preapproved safety measures. On the other hand, ASMs—such as traffic 

channelization devices that are less than the required length to be an

SSM—require individual review by the FRA. Public authorities must install 

safety measures at enough crossings within the proposed quiet zone so 

that the quiet zone’s risk index is at or below one of FRA’s two risk 

thresholds.21

 19Under some circumstances public authorities can establish quiet zones without 

additional SSMs or ASMs, where adequate safety features are already in place or where 

the risk of accidents is below certain FRA risk thresholds.

20“Channelization device” means a traffic separation system made up of a raised 

longitudinal “channelizer,” with vertical panels or tubular delineators that is placed 

between opposing highway lanes and is designed to alert or guide traffic around an 

obstacle or to direct traffic in a particular direction.

21FRA has two risk indexes, (1) the Risk Index with Horns and (2) the Nationwide 

Significant Risk Threshold. The Risk Index with Horns captures the average risk level if 

the train horn was routinely sounded at the grade crossings in the proposed quiet zone,

and the Nationwide Significant Risk Threshold captures the average nationwide level of 

risk of highway-rail-grade crossings equipped with flashing lights and gates and at which 

locomotive horns are routinely sounded. The Nationwide Significant Risk Threshold is 

variable and subject to change over time. FRA annually calculates the Quiet Zone Risk 

Index for each quiet zone established in relationship to the Nationwide Significant Risk 

Threshold and compares it to the current Nationwide Significant Risk Threshold. This 

review is not conducted for quiet zones established by having an SSM at every public 

grade crossing or by reducing the Quiet Zone Risk Index to the Risk Index with Horns. 

Within six months of FRA’s notification that the Quiet Zone Risk Index exceeds the 

Nationwide Significant Risk Threshold, the public authority must make a written 

commitment showing specific steps to lower the potential risk. A public authority then has 

3 years from the date of FRA’s notification to bring a quiet zone into compliance.
Page 9 GAO-18-97 Railroad Safety

Figure 2: Process Public Authorities Follow to Establish Quiet Zones

a

Each pedestrian crossing or private crossing to an active commercial or industrial site 

must be reviewed by a diagnostic team and equipped or treated in accordance with its

recommendations. The public authority must invite the state agency responsible for grade 

crossings’ safety and all affected railroads to participate in the diagnostic review. FRA is 

not required to participate in diagnostic reviews.

b

The Notice of Intent provides railroads and state agencies with an opportunity to provide 

comments and recommendations on the quiet zone. A complete and accurate U.S. 
Page 10 GAO-18-97 Railroad Safety

Department of Transportation Grade Crossing Inventory Form must be on file with FRA for 

all crossings within the quiet zone to reflect the current conditions at each crossing.

c

A Notice of Quiet Zone Establishment must be issued to FRA, applicable railroads, and 

relevant state agencies indicating a quiet zone is being established at least 21 days prior 

to the establishment date.

Throughout the process public authorities may work with a number of 

stakeholders who have roles and responsibilities related to grade 

crossings. These include:

• FRA: In addition to issuing rules and regulations governing train horns 

and quiet zones, FRA has staff—in headquarters and in FRA’s eight 

regional offices—that review public authority applications for use of 

ASMs, issue guidance on implementing federal regulations, answer 

questions from the public, and provide technical assistance related to 

the establishment of quiet zones. For example, FRA’s 19 regional 

GCMs serve as subject matter experts on the train horn regulations 

and respond to questions from public authorities, while FRA program 

officials approve ASMs and conduct required annual reviews of quiet 

zones established relative to the Nationwide Significant Risk 

Threshold to ensure they equal or fall below this risk index.

• Railroads: Railroads work with public authorities to: (1) identify 

appropriate safety measures at grade crossings; (2) participate in 

diagnostic review meetings when the quiet zone includes public, 

private, or pedestrian grade crossings; (3) receive and comment on 

public authority’s quiet zone notifications (e.g., the Notice of Intent and 

Notice of Quiet Zone Establishment); (4) install safety measures on 

railroad property; and (5) direct train crews not to sound horns in 

established quiet zones.

• State departments of transportation and rail regulatory agencies:

These agencies receive and comment on Notices of Intent, public 

authority applications, and Notices of Quiet Zone Establishment; 

review, and in some cases approve grade crossing modifications; and 

participate in diagnostic reviews.22

 22Most aspects of jurisdiction over grade crossings reside with the states. Within some 

states, responsibility is divided between several public agencies and the railroad. In other 

states, jurisdiction over grade crossings is assigned to a regulatory agency with various 

names such as the Public Utility Commission. These agencies are responsible for 

ensuring the safety of grade crossings within the states and, in some cases, approve any 

modifications to a grade crossing, such as adding SSMs. See U.S. Department of 

Transportation, FRA, Compilation of State Laws and Regulations Affecting Highway-Rail 

Grade Crossings, Fifth Edition (October 2009).
Page 11 GAO-18-97 Railroad Safety

• Private industry consultants: In some cases, public authorities hire 

consultants to provide subject matter expertise on establishing quiet 

zones. Consultants may perform such tasks as determining the 

feasibility of a quiet zone; arranging diagnostic reviews; assessing 

quiet zone risks; and identifying appropriate safety measures.

According to FRA officials, federal funding is available to reduce the risks 

of accidents at grade crossings, but funding specific to quiet zones is 

limited and no dedicated source exists. The primary source of federal 

funding to improve grade crossings’ safety is the Federal Highway 

Administration’s (FHWA) Railway-Highway Crossings (Section 130) 

Program, which received a set-aside of $230 million for fiscal year 2017 

from amounts authorized for the Highway Safety Improvement Program.23

While the funds are not specific to quiet zones, Section 130 funds may be 

used to upgrade crossing infrastructure, an upgrade that may result in a 

public authority’s being more easily able to establish a quiet zone. 

However, according to FRA program officials, the program is competitive 

and funding must be used for safety projects. They said projects are 

selected on a safety priority basis, and quiet zones are generally 

considered a quality of life issue, not a safety improvement. Hence, it is 

unlikely that many public authorities will obtain these funds to establish 

quiet zones. Further, the officials said that while other federal funding is 

available for which grade crossing improvements may be an eligible 

expense, none is dedicated to quiet zones.

According to FRA officials, limited federal funding is available because 

quiet zones are not a national issue. They produce highly localized 

quality-of-life benefits and little or no improvement in the level of safety at 

grade crossings, but rather the safety measures are installed to 

compensate for silencing the sound of a train horn at grade crossings.24

As a result, public authorities seeking to establish quiet zones generally 

fund the installation of SSMs and ASMs. Given limited funding, public 

authorities determine whether the benefits of establishing a quiet zone 

outweigh the costs to establish them.

 2323 U.S.C. § 130(e)(1)(A)(ii). Section 130 program funds are eligible for projects at all 

public grade crossings and apportioned to each state annually. Fifty percent of a state’s 

apportionment is dedicated to the installation of protective devices at grade crossings, 

whereas the remainder of funds can be used for hazard elimination projects, including 

protective devices. Section 130 projects are funded at a 90 percent federal share, with the 

state or the roadway authority funding the remaining 10 percent.

24See Congressional Research Service, The Federal Railroad Administration’s Train Horn 

Rule (June 3, 2013). 
Page 12 GAO-18-97 Railroad Safety

Benefits derived from establishing quiet zones and reducing noise from 

the train horn have not been quantified in research we reviewed or by the 

public authorities (i.e., communities) that we interviewed. Specifically, our 

review of literature did not identify any studies that had quantified the 

benefits resulting from public authorities establishing quiet zones at grade 

crossings where the horn was previously sounded. Further, FRA has not 

quantified benefits associated with quiet zones, but did note in its RFIA 

that quiet zones would likely result in localized quality-of-life benefits from 

silencing of the horn at locations where it had previously been sounded.25

Finally, none of the public authorities we interviewed have conducted any 

analysis that has quantified benefits associated with quiet zones or were 

aware of any studies that quantified these benefits.

While the benefits of quiet zones have not been quantified, the majority of 

stakeholders whom we interviewed stated that quiet zones do provide 

benefits for communities. The most commonly cited benefit (35 of 40 

stakeholders) was the reduction in noise due to the absence of routine 

sounding of the train horn. Stakeholders told us this noise reduction led to 

improvements in quality of life from, for example, the ability to sleep better 

at night, as well as a reduction in residents’ noise complaints. To a lesser 

extent, stakeholders also cited economic development and safety as 

benefits for communities. Almost half of the stakeholders (19 of 40) we 

interviewed told us that areas with new quiet zones saw an increase in 

economic development from such things as new businesses or residential 

developments. Similarly, almost half of the stakeholders (17 of 40) said 

 25FRA’s RFIA measured safety benefits resulting from eliminating whistle bans and 

requiring that trains horns be sounded at all grade crossings. The RFIA did not measure 

benefits that may result from establishment of a quiet zone to crossings for which train 

horns were previously sounded.

Benefits of Quiet 

Zones Have Not 

Been Quantified, and 

Costs Depend on 

Many Factors

While Benefits of Quiet 

Zones Have Not Been 

Quantified, Selected 

Stakeholders Highlighted 

Benefits for Communities
Page 13 GAO-18-97 Railroad Safety

that quiet zones increased safety along rail lines, given the addition of 

new safety measures at the grade crossings.

While the benefits associated with quiet zones have not been measured, 

more generally, researchers have analyzed the effect of transportation 

noise on property values and health to understand the effects.

26

• Property values: Our review identified two studies that analyzed the 

effect of freight train noise on property values in selected communities 

and found mixed results. In one study, the authors looked at the effect 

of a freight rail line on home prices and concluded that, while for

smaller homes results suggest a negative and statistically significant

effect on sale prices, results for medium and larger units were 

mixed.27 In the second study, the author examined the effect of a 

railroad’s decision to ignore whistle bans and found that proximity to 

rail lines and crossings had a negative and statistically significant 

effect on residential property values in some communities, with the 

effect varying depending on distance to the rail line.28 The author 

concluded that the crossing effects were largely temporary, because 

over time, buyers less sensitive to noise would likely move into the 

area, reducing or eliminating any long-term effect of the railroad’s 

decision. However, both of these studies have limitations, are based 

on data almost two decades old, and the results might not be 

representative of the economic effects associated with quiet zones.29

 26Transportation noise is generally considered undesirable but there is no well-defined 

market price for establishing its value. As a result, researchers may rely on indirect 

methods, such as changes in property values, as a proxy to understand this value.

27See Robert A. Simons and Abdellaziz El Jaouhari, “The Effect of Freight Railroad 

Tracks and Train Activity on Residential Property Values,” The Appraisal Journal, 72.3

(Summer 2004), 223. For this study, the authors used a model to estimate the effect of 

proximity to railroad tracks and crossings on the sale price of homes. The authors 

analyzed data from Cuyahoga County, Ohio. With respect to the effect of proximity to 

grade crossings, the study found mixed results, depending on size of the home and other 

factors.

28D. Clarke,“Externality Effects on Residential Property Values: The Example of Noise 

Disamenities,” Growth and Change, 37, 3 (September 2006). The author used a model to 

estimate the effect of one railroads’ (Conrail) decision to ignore whistle bans on residential 

property’s real sales prices in three U.S. counties. Counties were selected based on 

availability of data that spanned the period of Conrail’s decision to ignore whistle bans.

29These studies had two main limitations. First, the studies used a small population to 

conduct their research—one study used home sales data from one county and the other 

used data from three counties. Second, both studies were conducted some time ago, and 

relied on data from the late 1990’s, making the results almost 20 years old. 
Page 14 GAO-18-97 Railroad Safety

• Health effects: In 2002, FRA summarized available academic 

literature on the undesirable effects of noise—primarily focusing on 

transportation noise associated with aircraft, highways, and 

railroads.30 According to the research, transportation noise can cause 

undesirable psychological health effects, such as annoyance, and 

physiological health effects, such as hearing impairments and sleep 

disturbance on individuals.31

Total costs to establish quiet zones depend on many factors and vary 

widely.32 Prior to issuing regulations, in the RFIA, FRA identified the types 

of costs associated with establishing quiet zones that can be incurred by 

public authorities, states, railroads, and FRA. These factors included such 

things as upgrading signals at grade crossings; purchasing, installing, and 

maintaining safety measures like flashing lights and gates; developing, 

reviewing, and evaluating quiet zones; and designing public education 

and awareness efforts. The actual cost that public authorities incur to 

establish quite zones will vary and depend on these and other factors. 

Both FRA program officials and FRA guidance has stated that, in general, 

the factors that affect the costs include such things as the number of 

grade crossings in a quiet zone, the geography of the area in which the 

quiet zone is established, and the types of safety measures a public 

authority decides to install. For example, some grade crossings may 

require upgrades to constant-warning-time devices or installation of 

complex and costly SSMs (e.g., four-quadrant gates), whereas other 

grade crossings may require fewer upgrades or less complex safety 

measures (e.g., traffic channelization devices). In 2013, FRA published 

guidance for public authorities in which it estimated that the capital costs 

public authorities may incur to establish quiet zones may range from 

about $30,000 to more than $1 million per grade crossing, depending on 

the types of safety improvements and existing infrastructure at grade 

 30U.S. Department of Transportation, John A. Volpe National Transportation Systems 

Center, General Health Effects of Transportation Noise, FRA/RDV-03/01 (Cambridge, MA:

June 2002).

31The study did not isolate the effect of rail noise on individuals.

32Total costs refer to all direct (e.g., capital cost of safety measures) and indirect costs 

(e.g., administrative costs) associated with the establishment of the quiet zone.

Costs to Establish Quiet 

Zones Depend on Many 

Factors
Page 15 GAO-18-97 Railroad Safety

crossings.33 The RFIA stated that, because grade crossings may differ 

significantly, public authorities must analyze the characteristics of each 

and the safety measures needed to accurately estimate costs to establish 

quiet zones.

Public authorities we interviewed confirmed that the costs to establish 

quiet zones do vary and depend on many factors. All 13 public authorities 

we interviewed often said that in establishing quiet zones they incurred 

costs for identifying safety measures for grade crossings, purchasing and 

installing these safety measures, and maintaining quiet zones, among 

other things. According to the public authorities we spoke with in our 

review, the cost to establish quiet zones ranged from about $14,000 to 

several million dollars.34 However, this range also reflects different levels 

of quiet zone activity; for example, one public authority established a quiet 

zone at a single grade crossing, while another established a quiet zone 

that encompassed 60 grade crossings.

In addition, railroads, states, and FRA may incur costs as part of 

establishing quiet zones. For example, officials from seven of the eight

railroads we interviewed stated that they incur costs for such things as (1)

participating in diagnostic reviews, (2) commenting on Notice of Intents 

and Notice of Quiet Zone Establishments; and (3) notifying and training 

crews not to sound horns in quiet zones. States may also incur costs. 

Two states included in our review—California and Colorado—have public 

utility commissions that told us they are required to review and approve 

any modifications to grade crossings in their states, including those 

associated with quiet zones. Finally, FRA incurs costs related to quiet 

zones. This cost includes reviewing quiet zone applications, participating 

in diagnostic reviews when invited, and the time GCMs or other FRA staff 

 33FRA, Guide to the Quiet Zone Establishment Process: An Information Guide

(Washington, D.C.: September 2013). According to FRA program officials, these 

estimates are not an exact amount, but rather an “order of magnitude” cost estimate 

intended to give public authorities a rough sense of what quiet zones might cost per grade 

crossing. We did not validate these costs or the underlying methodology used to prepare 

these estimates.

34These cost estimates were provided by public authorities, and may not represent total 

costs to establish a quiet zone.
Page 16 GAO-18-97 Railroad Safety

spends providing technical assistance to public authorities and others on 

establishing quiet zones.35

While public authorities are generally responsible for paying the costs to 

establish quiet zones, about half of the public authorities we interviewed 

(10 of 13) said they obtained funding from outside sources to help pay for 

the zones, for example:

• Federal funds: Six of the public authorities we interviewed reported 

receiving federal funds to help establish their quiet zones.

36 In 

particular, one public authority that we interviewed reported receiving 

a $3.3 million Transportation Investment Generating Economic 

Recovery grant to establish a quiet zone.37 Alternatively, public 

authorities in the remaining five communities were eligible for grade 

crossing safety improvement efforts that were designated by the state 

through FHWA or other programs.38

• State or railroad funds: For three of the public authorities we 

interviewed, quiet zones were established in conjunction with larger 

state department of transportation highway or railroad projects and 

these entities paid a portion of the costs.

• Grade crossing incentive funds: Four of the public authorities we 

interviewed received grade-crossing incentive funds from railroads or 

state departments of transportation to close grade crossings that were 

part of a quiet zone.

• Private funds: In two communities, private investors provided 

financial assistance to public authorities for a quiet zone. For 

 35As discussed earlier, FRA is required to review applications when public authorities use 

ASMs or modified SSMs to establish quiet zones. According to FRA officials, about 10 

percent of new quiet zones require applications for FRA review.

36While several of the public authorities in our nongeneralizable sample obtained federal 

funds to help pay for their quiet zones, this funding may not be typical of other public 

authorities that have, or wish to establish, quiet zones. 

37Congress first authorized and appropriated funds for a national surface transportation 

infrastructure discretionary grant program in the American Recovery and Reinvestment 

Act of 2009 (Pub. L. No. 111-5, 123 Stat. 115, 203 (Feb. 17, 2009)). This program has 

become known as Transportation Investment Generating Economic Recovery.

38As stated earlier, FHWA Section 130 funds are not available to establish quiet zones. 

Rather, these funds are available to install protective devices at grade crossings that are 

designated high-risk for accidents.
Page 17 GAO-18-97 Railroad Safety

example, a private developer paid for a quiet zone in order to facilitate 

the building of residential developments.

Public authorities and other stakeholders that we spoke with reported 

several types of challenges with establishing quiet zones. These 

stakeholders noted three primary challenges, which included the cost to 

establish quiet zones, obtaining stakeholder cooperation, and the process 

to establish quiet zones. As aforementioned, public authorities generally 

incur costs to establish quiet zones, so cost plays a major role in a public 

authority’s decision of whether to pursue a quiet zone or not. The most 

commonly cited challenge was cost (29 of 40 stakeholders). In some 

cases, officials whom we interviewed reported that costs were the main 

reason that public authorities delayed or discontinued the process to 

establish a quiet zone.

In addition to cost, stakeholders cited two other primary challenges to 

establishing quiet zones—obtaining cooperation among quiet zone 

participants and the process for establishing quiet zones—and suggested 

a variety of improvements related to bolstering the process.

• Cooperation among quiet zone participants (18 of 40): Although 

stakeholders we spoke with cited a number of cooperation issues, 

including difficulties in getting private grade crossing owners to 

participate and lack of state cooperation, over half (10 of 18) cited 

cooperation between public authorities and railroads as a challenge. 

Such cooperation is important since both must typically work together 

to establish quiet zones. However, there are natural tensions between 

public authorities and railroads with respect to establishing quiet 

zones. As discussed earlier, stakeholders we spoke with supported 

quiet zones believing they not only maintain safety, but improve 

quality of life. On the other hand, all eight railroads told us that the 

train horn is the most effective safety measure.

• The process for establishing quiet zones (16 of 40): In general, the 

stakeholders we spoke with cited a variety of process related 

challenges, including that the train horn regulations are difficult to 

Selected Public 

Authorities and Other 

Stakeholders 

Reported Several 

Challenges in 

Establishing Quiet 

Zones and Suggested 

Potential 

Improvements
Page 18 GAO-18-97 Railroad Safety

understand, FRA waivers are difficult to obtain,39 and that the quiet 

zone process could be better explained by FRA. In particular, over 

half of the stakeholders whom said that process was a challenge (10 

of 16) explained that the quiet zone process was either difficult to 

understand or navigate or that the requirements to establish a quiet 

zone were confusing. For example, one public authority told us that

rules for establishing a quiet zone can be difficult to interpret and that 

this difficulty could impact public authorities’ establishment of quiet 

zones. Four of the 16 stakeholders also told us the process was time 

consuming and, in some instances, can take years to complete. FRA 

program officials said the turnaround time for FRA reviews depends 

on the quality of materials provided. They said it generally takes 90 to 

120 days for FRA to complete its review, but it can take longer if there 

is missing information or other problems with a public authority’s 

application, as is often the case.

Stakeholders we spoke to suggested three types of process-related 

improvements: administrative changes to improve the efficiency of the 

process, improvements to FRA’s role in the quiet zone process, and 

improvements to FRA guidance that public authorities use to establish 

quiet zones.

Administrative improvements: Twenty-five of the 40 stakeholders that 

we interviewed identified one or more types of administrative process 

improvements to improve the efficiency of the process for establishing 

quiet zones or better facilitate their establishment. These suggested 

improvements included:

• Making the quiet zone process more user-friendly (11 of 40 

stakeholders that offered suggestions related to the quiet zone 

process): Stakeholders we interviewed identified various 

improvements that could streamline some administrative requirements 

of the quiet zone process. These steps include standardizing or 

automating the quiet zone process, developing sample Notices of 

Intent or Notices of Quiet Zone Establishment that public authorities 

could use to input information, and making quiet zone materials 

 39Waivers of compliance with a provision of the regulations may be granted when the FRA 

Associate Administrator for Railroad Safety finds that a waiver is in the public interest and 

consistent with the safety of highway and railroad users. In general, to obtain a waiver 

from train horn regulatory provisions, two parties file a petition, the railroad owning or 

controlling operations over the railroad tracks crossing the public-highway-rail-grade 

crossing and the public authority that has jurisdiction over the roadway crossing the 

railroad tracks. 49 C.F.R, § 222.15. 
Page 19 GAO-18-97 Railroad Safety

available electronically.40 For example, GCMs in one FRA region told 

us that by standardizing the paperwork all regions would receive the 

same documents, a step that would make review easier. In addition, 

these officials said public authorities often forget to include key 

information in the Notice of Intent and with a standard form this may 

not occur.

• Requiring diagnostic reviews for all quiet zones (7 of 40): As 

discussed earlier, when there are private grade crossings that allow 

public access to active commercial or industrial sites or pedestrian 

grade crossings in a quiet zone, a diagnostic review is required.41 The 

regulations require public authorities to provide state agencies and 

affected railroads, among others, the opportunity to participate in 

diagnostic reviews. According to FRA program officials, FRA is not 

required to participate in diagnostic reviews. Diagnostic reviews 

evaluate conditions at proposed quiet-zone crossings and a 

diagnostic review team makes recommendations about measures that 

are needed to protect safety at these crossings. Seven stakeholders 

we interviewed suggested that diagnostic reviews should be required 

for all quiet zones, not just instances when there are private or 

pedestrian crossings. For example, one GCM told us conducting a 

review for all grade crossings provides a better idea of what safety 

measures are needed and is a prudent action to protect public 

safety.42

FRA’s Role in the Process: About half of the stakeholders we spoke 

with (21 of 40) suggested improvements related to FRA and its role in the 

quiet zone process:

• Increase FRA oversight and inspection of quiet zones (11 of 40): In 

general, these stakeholders believe FRA should be more involved 

with inspections and oversight of quiet zones, particularly between 

when a Notice of Quiet Zone Establishment is issued and when a 

quiet zone is established. Most of the railroad stakeholders we spoke 

with (6 of 8) believe there is a need for increased FRA involvement 

 40Federal train horn regulations require public authorities to prepare Notice of Intent and 

Notice of Quiet Zone Establishment documents.

4149 C.F.R. §§ 222.25(b)(1), 222.27(b). 

42According to FRA officials, a change to the train horn regulations would be necessary to 

require diagnostic reviews at all grade crossings. In addition, they said FRA has 

historically recommended that public grade crossings have a diagnostic review, even 

though it is not required.
Page 20 GAO-18-97 Railroad Safety

with quiet zones’ oversight. Among the railroad concerns were that 

without additional FRA oversight, quiet zones may not achieve 

compliance with the train horn regulations, and that public authorities 

may not actually install the safety measures identified in the Notice of 

Quiet Zone Establishment. A GCM in one FRA region told us that 

officials discovered noncompliant safety measures and missing signs 

after quiet zones had been established in this region, and that safety 

measures that were supposed to be installed were not. We discuss 

quiet zone oversight issues later in this report.

• Expedite FRA’s review of quiet zone applications (10 of 40): As 

discussed earlier, FRA plays a role in the quiet zone process, in part, 

by reviewing quiet zone applications when ASMs are used. The 10

stakeholders felt that FRA should expedite its review process. For 

example, a GCM in one FRA region suggested FRA shorten the 

review time by developing a list of frequently used ASMs and their 

safety effectiveness ratings and posting them online, a process that 

would save FRA time when reviewing ASMs.

Guidance about the process: Finally, stakeholders we spoke with 

suggested guidance on the quiet zone process could be improved (17 of 

40).

• In particular, 13 of the 17 stakeholders whom offered suggestions 

about guidance said that FRA’s quiet zone guidance should be clearer 

or that training about the quiet zone process is needed. As previously 

discussed, some stakeholders told us the quiet zone process is 

difficult to understand or navigate, or that FRA could better explain the 

process. In particular, two public authorities suggested some form of 

step-by-step guide is needed to better describe the process, and 

GCMs in three FRA regions also suggested classes or other types of 

education were needed to better help public authorities understand 

the quiet zone process. According to FRA program officials, FRA’s 

quiet zone guidance consists of its user guide and a document on 

how to create a quiet zone.43 The train horn regulations also specifies 

how public authorities are to establish quiet zones and includes steps 

to follow under the public authority designation or public authority 

application processes.

Moving forward, FRA is in the process of conducting a retrospective 

regulatory review and deciding what, if any, changes may be needed. In 

March 2016, FRA issued a Notice of Safety Inquiry, which, according to 

 43FRA, How to Create a Quiet Zone (posted online September 27, 2012).
Page 21 GAO-18-97 Railroad Safety

FRA, is a retrospective review of the train horn regulations. The Notice of 

Safety Inquiry solicited comments about many aspects of the train horn 

regulations, including whether FRA can decrease the barriers public 

authorities encounter when establishing a quiet zone. Among other 

things, the inquiry seeks comments about whether there should be an 

online process for submitting notices and other required quiet zone 

paperwork, whether diagnostic reviews should be required for all quiet 

zones, and if the regulations should be amended to include common 

ASMs in the list of approved SSMs. The Inquiry is also looking at other 

aspects of the quiet zone process and guidance. As of July 2017, FRA 

was still in the process of reviewing comments received in response to 

the notice. FRA program officials did not indicate what, if any, changes 

may result from this inquiry, but said any changes that are made would be 

handled through a rulemaking. However, FRA program officials noted that 

a rulemaking would not be necessary for the agency to provide public 

authorities with additional tools to aid in the development of a quiet zone, 

such as guidance.
Page 22 GAO-18-97 Railroad Safety

One way FRA evaluates the effectiveness of its train horn regulations is 

through conducting analyses of data on the safety of grade crossings in 

quiet zones. Those analyses show that grade crossings in quiet zones 

are generally as safe as the same grade crossings when the train horn 

was sounded. Specifically, FRA conducted analyses in 2011 and 2013 to 

assess whether there was a statistically significant difference in the 

number of accidents before and after implementation of quiet zones.44

The results showed that there was generally no statistically significant 

difference in the number of accidents that occurred before and after quiet 

zones were established. To conduct the analyses, FRA grouped quiet 

zones by the number of years of available data since establishment of the 

quiet zone, using an equal number of months before and after 

 44FRA, Office of Railroad Safety Grade Crossing Division, 2011 Analysis of the Safety 

Impact of Quiet Zones at Highway-Rail Grade Crossings (Washington, D.C.: July 2011) 

and FRA, Office of Railroad Safety Grade Crossing Division, 2013 Analysis of the Safety 

Impact of Quiet Zones at Highway-Rail Grade Crossings (Washington, D.C.: February 

2014).

FRA Has Conducted 

Analyses of Safety in 

Quiet Zones and Is 

Formalizing Quiet 

Zone Inspections, but 

Limitations Exist

FRA’s Analyses Generally 

Indicate That Grade 

Crossings in Quiet Zones 

Are As Safe As The Same 

Grade Crossings When 

the Train Horn Was 

Sounded, but 

Methodology Has 

Limitations
Page 23 GAO-18-97 Railroad Safety

establishment.45 FRA’s analyses in 2011 and 2013 included 359 and 203 

quiet zones, respectively.46

While FRA’s analyses of quiet zones generally showed that grade 

crossings in quiet zones were as safe as the same grade crossings when 

the train horn was sounded, in 2013 FRA identified one exception that 

FRA program officials reported resolving in a subsequent analysis. 

Specifically, while FRA’s 2011 analysis did not show any differences in 

safety after establishment of the quiet zones, in 2013 FRA concluded that 

for quiet zones established from May 2010 through April 2011, there was 

a statistically significant increase in the number of accidents that occurred 

after the establishment of the quiet zones. Specifically, FRA found that 

accidents doubled from 11 accidents before establishment of the quiet 

zones to 22 accidents following the establishment of the quiet zone. After 

that finding, FRA program officials conducted a preliminary analysis for 

2017 and reported that the results did not show a statistically significant 

increase in accidents for any period of quiet zones, including those 

established from 2010 through 2011.47 In addition to looking at quiet 

zones by establishment year, FRA’s 2013 analysis also grouped quiet 

zones by how they were established, such as with safety measures at all 

crossings or against FRA’s risk indexes. Results from this analysis did not 

 45For example, in 2013 FRA grouped quiet zones by the number of years of available 

incident data before and after establishment, using a paired t-test to compare the mean 

number of incidents for a time interval of 1, 2, 3, 4, 5, 6, or 7 year(s) before the quiet zone 

was established to the mean number of incidents during an equal time interval after 

establishment. 

46In 2011, FRA had data on 434 quiet zones; however, 75 were dropped because they did 

not have a Notice of Quiet Zone Establishment date or because one year of observable 

data were not available. In 2013, FRA had data on 575 quiet zones; however, 373 quiet 

zones were dropped because they were in the Chicago region and exempted, they had 

inconsistent data, they did not have proper Notice of Quiet Zone Establishment 

information, or because one year of observable data were not available. In its 2011 

analysis, FRA noted that it had a number of data quality issues. As a result, FRA program 

officials told us they implemented additional safeguards in 2013 and reduced the number 

of observations dropped due to errors to less than one percent.

47FRA’s analyses grouped quiet zones by year of establishment. However, because these 

analyses were conducted in different months of the year, the analyses did not compare 

the exact same grouping of quiet zones for each year. For example, for the 2007-2008 

time period, FRA’s 2011 analysis included quiet zones established from February 2007 

through January 2008, whereas the 2013 analysis included quiet zones established from 

May 2007 through April 2008.
Page 24 GAO-18-97 Railroad Safety

show an increase in accidents by any establishment method analyzed.48

As a result, FRA program officials told us that they believe the result in 

2013 for quiet zones established from 2010 through 2011 was likely an 

anomaly and that those quiet zones are as safe as other crossings.

Before-and-after analysis is a methodologically acceptable practice, but 

the reliability of the results decrease over time because unlike other types 

of analyses, they do not control for factors that may change over time. In 

particular, FRA’s analyses assume that the number of accidents 

experienced before the quiet zone is established is a good estimate of the 

number of accidents that would be expected in the future had the quiet 

zone not been established. However, FRA’s before-and-after analyses 

have limitations because, unlike other methodologies, they do not take 

into account changes to characteristics of grade crossings over time. For 

example, a multivariate method can control for changes to characteristics 

at grade crossings that may impact safety. These characteristics can 

include changes to train or vehicle traffic, train or vehicle speeds, time of 

day when train activity occurs, number of highway lanes, the number of 

tracks in use, or other changes to surrounding roads or infrastructure at a 

crossing. For example, if train or vehicle traffic increased over time, it is 

possible that the number of incidents would increase, while the risk of an 

accident would stay the same. Specifically, closing a grade crossing near 

a quiet zone or increases in traffic from new businesses around a quiet 

zone could increase traffic after the establishment of a quiet zone; 

however, these changes would not be factored into FRA’s current 

methodology for conducting safety analyses. This inherent limitation is 

exacerbated over time, because the assumption that there would be no 

changes to relevant characteristics of the grade crossings is less likely to 

be the case as more time passes.49

FRA also conducts annual reviews of selected quiet zones to ensure their 

safety, and FRA program officials told us that this review further validates 

its before-and-after analyses. As mentioned previously, FRA conducts 

 48FRA grouped each quiet zone into one of 19 quiet zone establishment methods. Since 

before-and-after analyses require a minimum amount of data for robust results, FRA only 

analyzed groups that had at least 15 accident data points. As a result, FRA analyzed 6 of 

the 19 groups and found that none of these groups had a statistically significant decrease 

in safety,

49Since FRA divides the total number of accidents in each group of quiet zones by the 

number of quiet zones in that group, another limitation of FRA’s analyses is that they may 

mask changes in the number of incidents at any particular quiet zone.
Page 25 GAO-18-97 Railroad Safety

annual reviews of quiet zones established against the Nationwide 

Significant Risk Threshold because the measure is variable and subject 

to change over time.50 According to FRA program officials, about 11 

percent of all quiet zones are established against the Nationwide

Significant Risk Threshold and are thus included in this annual review. To 

ensure that established quiet zones fall at or below the Nationwide 

Significant Risk Threshold, FRA is required to recalculate this measure on 

an annual basis and notify a public authority if the Quiet Zone Risk Index 

no longer falls at or below the threshold.51 By doing so, FRA program 

officials told us that they are further validating that the grade crossings in 

quiet zones are as safe as other grade crossings. While this annual 

review may provide FRA with additional support that grade crossings in 

quiet zones are as safe as others, it does not address the underlying 

limitations of a before-and-after analysis.

While the reliability of a before-and-after analysis may decrease over 

time, FRA has no plans to revise its methodology. In fact, as mentioned 

previously, FRA program officials told us that preliminary results for their 

2017 safety study mirror results from 2011, showing that there was no 

statistically significant difference in accidents before and after the 

establishment of quiet zones. According to FRA program officials, the 

agency is not required to conduct this analysis, but moving forward,

program officials plan to conduct the same analysis on a biennial basis to 

internally validate that grade crossings in quiet zones are as safe as 

others.

By continuing to rely on the current methodology, FRA’s future analyses 

may continue to provide the agency with information that does not 

account for changes in characteristics of grade crossings over time. The

Standards for Internal Control in the Federal Government states that 

management should use quality information to make informed decisions. 

This requirement can be satisfied by, for example, obtaining relevant data 

from reliable sources, obtaining that information on a timely basis, and 

processing that data into quality information that accurately represents 

 50According to FRA program officials, reviews for quiet zones established with safety 

measures at all crossings or established against the Risk Index with Horns are not 

required because these measures are intended to fully compensate for the lack of the 

train horn. 

51As part of this process public authorities are required to update information on the quiet 

zone about every three years. These updates will incorporate any changes in risk level 

due to vehicle or train traffic, among other things.
Page 26 GAO-18-97 Railroad Safety

what it purports to represent. Furthermore, a previous FRA study that the 

agency relied on in developing the final rule has reported that changes in 

grade crossings’ characteristics can affect the results of analyses used to 

predict accidents at grade crossings.52 As a result, FRA’s Rail-Highway 

Crossing Resource Allocation Procedures recommended that analyses 

used to predict accidents at grade crossings only include accident data 

for the most recent 5 years because older accident history information 

may be misleading due to changes that occur in grade crossings’

characteristics over time.53 While FRA’s recommendation was not 

developed to analyze the safety of grade crossings in quiet zones, the 

agency’s recommendation that accident data older than 5 years may be 

misleading because of changes that occur to grade crossings’

characteristics over time is relevant to those analyses. Nevertheless, FRA 

program officials told us that they have no plans to revise the 

methodology because it effectively compares the safety of grade 

crossings in quiet zones to other grade crossings. By continuing to use 

the same methodology, the agency may be missing an opportunity to fully 

understand the safety of grade crossings in quiet zones.

In addition to conducting studies, FRA also oversees quiet zones by 

inspecting them to ensure their safety and compliance with train horn 

regulations. According to FRA program officials, FRA is not required to 

inspect quiet zones; rather, public authorities, in conjunction with the 

railroads, are responsible for maintaining quiet zones and ensuring 

 52FRA, North Carolina “Sealed Corridor” Phase I U.S. DOT Assessment Report: Report to 

Congress, (Washington, D.C.: August 2001). 

53FRA documentation states the most accurate predictions, in theory, will result from the 

use of all the available accident history, assuming crossing characteristics remained 

constant. However, the extent of improvement is minimal if data for more than 5 years are 

used. It is therefore recommended that only data for the most recent 5 years of accident 

history be used. This ensures good performance from both the accident prediction formula 

and use of the most relevant data. Accident history information more than 5 years old may 

be misleading because of changes that occur to crossing characteristics over time. If it is 

known that a significant change has occurred to a crossing during the most recent 5 

years, such as a warning device upgrade, only the accident data since the change should 

be used. See FRA, Rail-Highway Crossing Resource Allocation Procedure User’s Guide, 

Third Edition, DOT / FRA/ OS -87/ 10 (Washington, D.C.: August 1987).

FRA Has Taken Steps to 

Formalize Quiet Zone 

Inspections, but Lacks 

Formal Guidance
Page 27 GAO-18-97 Railroad Safety

compliance with train horn regulations.54 Until recently, FRA has utilized 

its GCMs to, among other things, informally inspect quiet zones and work 

with public authorities to resolve issues affecting the safety of quiet 

zones—issues such as foliage covering signage, maintenance issues 

with safety devices, or outdated pavement markings.55 In fact, GCMs in 

all eight regions told us that they informally inspect quiet zones.56

According to FRA program officials, the agency has recently identified the 

need for “more eyes on the ground” to more systematically address 

maintenance issues within quiet zones and to ensure compliance with 

train horn regulations.57 As a result, FRA is transitioning its informal 

inspection program for quiet zones to a more formal inspection process.

As part of this transition, FRA has taken steps to hire and train new 

inspection staff. In May 2017, FRA program officials told us that they were 

in the process of hiring Grade Crossing Inspectors (Inspectors), who 

would be responsible for conducting quiet zones inspections. In particular, 

Inspectors would be responsible for, among other things, ensuring 

compliance with (1) the train horn regulations, (2) emergency notification 

requirements at grade crossings, and (3) requirements to submit grade 

crossing inventory forms. Subsequently, FRA program officials told us in 

 54While the train horn regulations do not require physical inspections of quiet zones by 

FRA, public authorities, or railroads, FRA program officials told us that the regulations do 

provide FRA with the authority to conduct inspections of quiet zones and, if warranted, 

terminate a quiet zone or fine a public authority or railroad for violations. In addition, FRA 

program officials told us public authorities must certify that the Notice of Quiet Zone 

Establishment is accurate and provide periodic updates that contain written affirmations 

that safety measures within the quiet zone continue to comply with governing regulations.

55As mentioned previously, as of August 2017, FRA officials told us that they employed 19 

GCMs across eight regions that are responsible for, among other things, serving as 

subject matter experts on FRA regulations governing the use of train horns and quiet 

zones and coordinating regional assistance to public authorities interested in establishing 

quiet zones.

56We found, however, that how and when GCMs conducted these informal inspections 

varied significantly. For example, GCMs in one region told us they informally inspect quiet 

zones primarily when problems arise, whereas GCMs in another region told us they 

informally inspect all quiet zones in their region every three years using a checklist they 

developed.57As of August 2017, FRA had not terminated any quiet zones because of 

violations or fined any entities for quiet zone violations.

57As of August 2017, FRA had not terminated any quiet zones because of violations or 

fined any entities for quiet zone violations.
Page 28 GAO-18-97 Railroad Safety

August 2017 that they planned to hire 24 new Inspectors.58 As of August 

2017, FRA had also developed the Inspector training curriculum, and 

began training three Inspectors. FRA program officials expressed 

uncertainty over when the remaining 21 Inspectors will be hired because 

of uncertainty regarding FRA’s hiring and training priorities, among other 

things. In September 2017, FRA program officials told us that one of the 

newly hired Inspectors had completed the training and had begun 

inspecting quiet zones.

While FRA has started conducting formal quiet-zone inspections, we 

found that FRA has not developed guidance on how the inspections 

should be conducted, including guidance on how frequently these 

inspections should be conducted and what should be examined. As a 

result, such guidance is not included as part of the training curriculum 

developed for Inspectors. According to FRA program officials, this 

guidance has not been developed because program officials are still 

finalizing the inspection program. Although no guidance has been 

developed, FRA program officials told us that they are considering

inspecting all new quiet zones between when the public authority submits 

a Notice of Quiet Zone Establishment and when the quiet zone is 

established. Additionally, FRA program officials told us that existing quiet 

zones would be inspected based on mission requirements, risk, and the 

availability of resources, but ideally every 3 years. With respect to how 

the quiet zones are to be inspected, FRA program officials said they plan 

to develop guidance for Inspectors that is akin to the other FRA safety 

disciplines.59 FRA program officials told us that they are working toward 

establishing an Audit Division, which would be responsible for developing 

this guidance. However, as of August 2017, FRA program officials had 

not provided a timeline for when this division or guidance would be 

completed.

58Over this same time period, FRA officials told us that they will be simultaneously 

phasing out GCMs through attrition and retirement. In addition to hiring Inspectors, FRA 

also plans to hire Grade Crossing Specialists who will also have a role with inspecting 

quiet zones. However, as of August 2017, FRA program officials told us they were in the 

process of developing the Grade Crossing Specialist’s position description and were 

unsure when these individuals will be hired. 

59FRA has developed a manual for each of its other five disciplines. For example, FRA’s 

manual for the operating practices discipline includes: pertinent laws and regulations, 

inspector best practices, field-reporting procedures and forms, and illustrative examples of 

non-compliance issues. 
Page 29 GAO-18-97 Railroad Safety

The absence of guidance on inspections is inconsistent with internal 

control standards. Specifically, the Standards for Internal Control in the 

Federal Government states that management should implement control 

activities through its policies that document each unit’s responsibility, or 

further delineates day-to-day procedures.60 These procedures may also 

include the timing of when a control activity occurs and state that 

management should communicate these policies to its staff. Without this 

type of guidance, FRA cannot have reasonable assurance that 

inspections are being conducted consistently across FRA’s eight regions 

and as FRA intends.

Grade crossing collisions are one of the leading causes of fatalities in the 

railroad industry, and ensuring safety in these areas, including those 

within quiet zones, is a vital part of FRA’s mission. While public 

authorities are primarily responsible for safety in quiet zones, FRA can 

help ensure that grade crossings in quiet zones are as safe as others. 

However, the methodology FRA uses to assess the safety of quiet zones 

has limitations because it does not account for changes to grade 

crossings’ characteristics over time. By continuing to rely on this 

methodology, FRA may be missing an opportunity to ensure that 

established quiet zones are providing the same level of safety as when 

train horns were sounded.

In addition to its safety studies, FRA is also taking steps to formalize its 

process for conducting physical inspections of quiet zones. While FRA 

has started hiring and training a few Inspectors, it lacks guidance on how 

and when quiet zone inspections are to be performed. Without this 

guidance, FRA cannot ensure that quiet zones will be inspected 

consistently across FRA’s eight regions.

We are making the following two recommendations to FRA:

The Administrator of FRA should revise the methodology for the analysis 

of safety in quiet zones to take into account relevant changes over time—

including changes in train and automotive traffic, or in the physical 

characteristics of the grade crossing. (Recommendation 1)

60GAO-14-704G. 

Conclusions

Recommendations for 

Executive Action
Page 30 GAO-18-97 Railroad Safety

The Administrator of FRA should develop guidance for Inspectors on the 

nature and frequency of quiet zone inspections. (Recommendation 2)

We provided a draft of this report to the Department of Transportation for 

review and comment. The department provided a written response (see 

app. II), as well as technical comments that we incorporated as 

appropriate. The department concurred with the second recommendation 

regarding developing guidance for quiet zone inspectors and partially 

concurred with the first recommendation regarding revising the

methodology for analyzing the safety of quiet zones. The department said 

it would consider our recommendation to revise its methodology as it 

explores options for updating its methodology. 

We are encouraged that FRA is willing to consider revising its 

methodology for analyzing the safety of grade crossings in quiet zones. 

However, we continue to believe that our recommendation is valid and

that to fully understand quiet zone safety FRA needs to revise its 

methodology to account for relevant characteristics of quiet—zone grade 

crossings. As we state in the report, the reliability of FRA’s current 

methodology will likely decrease over time because it does not control for 

relevant changes to grade crossings in quiet zones including changes to 

vehicle or train traffic or speeds. These and other factors are critical 

determinants of grade-crossing safety. Further, developing a 

methodology that incorporates characteristics that affect safety at grade 

crossings in quiet zones may also provide FRA insight into the safety of

grade crossings more generally. Since grade-crossing accidents are a 

major source of fatalities and, according to the department, are expected 

to increase as train- and highway-traffic increases, it will become 

increasingly important to have reliable information about grade-crossing 

safety, both in quiet zones and across grade crossings more generally.

Agency Comments 

and Our Evaluation
Page 31 GAO-18-97 Railroad Safety

We will send copies of this report to appropriate congressional 

committees, the Secretary of Transportation, and the Administrator of the 

Federal Railroad Administration. In addition, we will make copies 

available to others upon request, and the report will be available at no 

charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or flemings@gao.gov. Contact points for our Office 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix IV. 

Susan A. Fleming

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and

Methodology

Page 32 GAO-18-97 Railroad Safety

The Fixing America’s Surface Transportation Act included provisions for 

GAO to review the effectiveness of the Federal Railroad Administration’s 

(FRA) final rule governing the use of train horns at highway-rail grade 

crossings.1 The objectives of this report were to determine: (1) what is 

known about the benefits and costs of quiet zones,2 (2) what challenges, 

if any, public authorities and others encounter in establishing quiet zones, 

and (3) how, if at all, FRA is evaluating the effectiveness of federal train 

horn regulations.3 The scope of this report was limited to new quiet 

zones—that is, quiet zones that were established since FRA published 

the final rule in August 2006. Federal regulations govern the use of train 

horns at public-highway-rail-grade crossings (grade crossings) and 

provide public authorities4

—typically a city, town, or county—with the 

opportunity to create quiet zones where train horns are not sounded. We 

focused on new quiet zones to better understand the benefits, costs, 

challenges, and safety impacts associated with the regulations.

To obtain information about quiet zones, we reviewed FRA’s data on 

quiet zones established from 2005 through 2017. To assess the reliability 

of these data, we examined FRA’s reports, analyzed the data to identify 

any outliers, and interviewed FRA officials about how the data were 

collected and used. We determined that the data were sufficiently reliable 

for our purposes.

For each of our objectives, we reviewed pertinent law and FRA 

regulations and documents; interviewed FRA program officials in 

1

Pub. L. 114-94 § 11403(a) (2015).

2

A “quiet zone” is a section of rail line that is at least one-half mile in length that contains 

one or more consecutive public grade crossings at which train horns are not routinely 

sounded when approaching the grade crossings. Public grade crossings are locations 

where a public highway, road, or street crosses one or more railroad tracks at-grade.

3The final rule was codified in parts 222 and 229 of Title 49, Code of Federal Regulations.

An interim final rule was issued in December 2003. The final rule was initially issued in 

April 2005; however, after petitions for reconsideration were received, a revised final rule 

was issued in August 2006. 71 Fed. Reg. 47614 (Aug. 17, 2006). The train horn 

regulations also included provisions for pre-rule quiet zones—these are grade crossings at

which state statutes or local ordinances restrict the routine sounding of train horns or at

which locomotive horns did not sound due to formal or informal agreements between the 

public authority and the railroad(s) prior to the final rule. The train horn regulations

excludes about 390 crossings in the Chicago Region (called the “Chicago Region 

Exemption”), which were governed by the Illinois Commerce Commission.

4

Public authorities are the entity responsible for traffic control or law enforcement at-grade 

crossings.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-18-97 Railroad Safety

headquarters; and conducted in-depth interviews with a nongeneralizable 

sample of 40 stakeholders. This sample included stakeholders from 8 

freight railroads, 5 private industry consulting firms with experience 

helping public authorities establish quiet zones, 6 state agencies, 13 

public authorities within these six states, and FRA Grade Crossing 

Managers (GCMs) in each of FRA’s 8 regions. The railroads selected 

included all seven class I railroads, plus the Florida East Coast Railway.5

The latter was selected due to its previous experience with whistle bans,

and it was located in a state where we conducted interviews. The private 

industry consultants were selected based on several factors, including (1) 

experience with assisting public authorities in establishing quiet zones, (2) 

recommendations from FRA and other stakeholders we interviewed, and 

(3) geographic dispersion.

We selected six states as part of a nongeneralizable sample for 

interviews. These states included California, Colorado, Florida, Illinois, 

Maryland, and Texas. The states were selected based on a variety of 

factors, including the number of new quiet zones and the number of grade 

crossings in new quiet zones. Five of the six states accounted for about 

48 percent of new quiet zones (California, Colorado, Florida, Illinois, and 

Texas). We also conducted interviews in Maryland before we conducted 

other interviews to test our interview protocol. Maryland was selected for 

this purpose to, among other things, minimize resources. Within these 

states, we conducted interviews with 13 judgmentally selected public 

authorities (see table 1). The public authorities were also selected based 

on factors such as the number of new quiet zones and recommendations 

from FRA and other stakeholders we interviewed.

 5

The freight railroad industry is divided into three classes based on annual operating 

revenues, as determined by the Surface Transportation Board. For 2016, this revenue 

threshold was at least $447.6 million for class I railroads, at least $35.8 million for class II 

railroads, and less than $35.8 million for class III railroads.
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-18-97 Railroad Safety

Table 1: States and Public Authorities Included in GAO’s Review

State Public authority

California Richmond

Rocklin

Colorado Commerce City

Denver (Regional Transportation District)

Fort Collins

Windsor

Florida Baldwin

Broward County

Illinois Galesburg

Oak Lawn

Maryland Montgomery County

Texas Aledo

Fort Worth

Source: GAO. | GAO-18-97

For all our objectives we also conducted a literature review of pertinent 

studies in scholarly/peer-reviewed journals, conference papers, non-profit 

or think tank publications, and trade publications or industry articles to 

identify research on quiet zones. We restricted our review to results 

published between January 1, 1996, and October 17, 2016, and our 

search yielded 99 results. Of these 99 results, we reviewed each abstract 

or full article if available, to determine whether it was relevant to any of 

our objectives. Our analysis identified 10 results pertaining to safety, 11 

results related to benefits and costs, and 1 result related to challenges.6

With respect to the articles related to costs and benefits, we also looked 

at citations within the studies we reviewed to identity whether any of these 

were relevant to our objective on costs and benefits of quiet zones. Using 

this approach we identified one additional study.7 Each abstract was 

reviewed by two analysts to determine whether it seemed relevant. 

Where disagreement existed with respect to whether the abstract was 

relevant, we included the abstract in our request for the complete study. 

We then developed criteria/requirements for each objective and reviewed 

 6

As of February 2017, the result related to challenges could not be obtained through a 

U.S. library lender. 

7

See D. Clark, “Externality Effects on Residential Property Values: The Example of Noise 

Disamenities,” Growth and Change, Vol. 37, No. 3 (September 2006). This paper was 

cited in FRA’s RFIA. 
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-18-97 Railroad Safety

each study against our criteria/requirements. Namely, we were only 

interested in studies that quantified the benefits or costs of quiet zones or 

that used data or analytics to measure safety at grade crossings in quiet 

zones or compared safety at-grade crossings in quiet zones to grade 

crossings where train horns sound. Further, each study was reviewed by 

an analyst and a statistician or economist to determine its relevance.8

With respect to our objective on the effectiveness of the train horn 

regulations, we determined that none of the studies met our underlying 

criteria. Specifically, none of the studies measured the safety at grade 

crossings in quiet zones or compared the results to grade crossings 

where the train horn sounded. Conversely, with respect to our objective 

on the costs and benefits of quiet zones, we determined that six studies 

were relevant.9 To assess the reliability and methodological soundness of 

the studies we determined were relevant, we compared the studies with 

general guidelines based on standards for assessing research and 

analysis from the literature, past GAO reports on evaluating research 

programs, and our internal expertise in research design. These guidelines 

include, for example, examining a study based on: (1) the extent to which 

it was well designed and the methodology supports the objectives; (2)

whether the assumptions were reasonable and explicitly stated; (3) 

whether the study used the best available data; and (4) whether the 

conclusions and recommendations were balanced and supported by data 

analysis.

To determine what is known about the benefits and costs of quiet zones, 

we reviewed the literature search discussed above and analyzed any 

studies obtained using the methodology described above. We also 

reviewed FRA’s Regulatory Evaluation and Regulatory Flexibility 

Assessment for Use of Locomotive Horns at Highway-Rail Grade 

 8

Studies related to the safety of quiet zones were reviewed by an analyst and statistician, 

whereas studies on the costs and benefits of quiet zones were reviewed by an analyst and 

economist. 

9

One of these results, U.S. Department of Transportation, Research and Special 

Programs Administration, John A. Volpe National Transportation Systems Center, 

Environmental Measurement and Modeling Division, General Health Effects of 

Transportation Noise, DTS-34-RR297-LR2, FRA/RDV-03/01 (Cambridge, MA, June 

2002), was not a study but rather a summary of academic literature on the effects of 

transportation noise. As a result, we did not critique this study, but rather summarized the 

high level findings. Two of the studies we identified related to costs and benefits could not 

be secured through a U.S. library lender. Finally, one of the studies we reviewed did not 

meet our standards for data reliability, so we eliminated it from our analysis.
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-18-97 Railroad Safety

Crossings Final Rule (RFIA).10 The RFIA was issued before the final rule 

and analyzed the potential economic effects of requiring the train horn to 

be sounded at all public grade crossings, of eliminating whistle bans, and 

of providing conditions under which the train horn can be silenced atgrade crossings. To review the RFIA, we compared it to selected 

principles from Office of Management and Budget’s (OMB) guidance for 

developing regulatory analyses.11 These principles included whether the 

analysis considered alternatives; whether the analysis estimated the 

incremental effect of the rule compared to a business-as-usual baseline; 

and whether the analysis analyzed uncertainty. In evaluating the RFIA, an 

analyst and economist independently reviewed the analyses and 

subsequently came to consensus about each element’s adherence to 

OBM guidance. We also reviewed FRA’s September 2013 user guide for 

quiet zones.12 This guide provides a high-level overview of the quiet zone 

process, including an estimated cost range to establish quiet zones. We 

discussed the cost range with FRA, including the source of the 

information and its reliability. Since FRA program officials told us it was 

an “order of magnitude” estimate and not meant to represent actual costs 

to establish quiet zones, we did not determine the reliability of the 

information. As a result, the cost range information is used for illustrative 

purposes only, and we included a disclaimer about its reliability. Finally, 

we interviewed FRA GCMs in all eight of FRA’s regional offices, states, 

public authorities, railroads, and private industry consultants about the 

benefits and costs of establishing quiet zones. Some of these 

stakeholders provided information about costs to establish quiet zones, 

but this was anecdotal, and we did not attempt to verify its completeness 

or accuracy.

To determine the challenges encountered by public authorities and other 

stakeholders in establishing quiet zones and improvements stakeholders 

suggested to the quiet zone process, we interviewed FRA GCMs, states, 

 10FRA, Regulatory Evaluation and Regulatory Flexibility Assessment for Use of 

Locomotive Horns at Highway-Rail Grade Crossings Final Rule (49 C.F.R. Parts 222 and 

229) (Washington D.C.: July 21, 2003).

11Office of Management and Budget: Circular A-4, Regulatory Analysis (Washington, D.C.: 

Sept. 17, 2003); and Office of Management and Budget, Circular No. A-94 Revised, 

Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs

(Washington, D.C.: Oct. 29, 1992).

12FRA, Guide to the Quiet Zone Establishment Process: An Information Guide, Federal 

Railroad Administration, Highway-Rail Crossing and Trespasser Programs Division 

(Washington, D.C.: September 2013).
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-18-97 Railroad Safety

public authorities, railroads, and private industry consultants. We asked 

these stakeholders to identify the primary challenges in establishing quiet 

zones and for suggested improvements to the quiet zone process. We 

then analyzed the information obtained to identify common themes of 

challenges or suggested improvements. Based on this analysis, an initial 

list of categories for each challenge and improvement was then 

developed along with their definitions. The definitions identified specific 

types of comments to be included in each challenge or improvement 

category. After reviewing the initial list for overlaps and duplication, as 

well as to keep the list manageable, a final consolidated list was 

developed that consisted of eight types of challenges and seven types of 

improvements (see table 2). Using this list, an analyst then reviewed each 

interview and judgmentally assigned the information into one of the 

categories. A second analyst then independently reviewed these 

assignments using the consolidated list of categories and definitions. Any 

differences were then reconciled by the two analysts.13

 13Most stakeholders identified more than one challenge or improvement during an 

interview, and these were reflected in each of the appropriate categories.
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-18-97 Railroad Safety

Table 2: Categories of Quiet Zone Challenges and Categories of Improvements Suggested by Stakeholders and Definitions

Category of challenge/improvement Definition 

Challenges

Funding/cost Items related to funding or cost of quiet zones or the process of establishing 

quiet zones.

Stakeholder cooperation Items related to stakeholders, including mentions of coordination, cooperation, 

participation, delays, and similar items. 

Process related Items related to the quiet zone process from the initial identification of grade 

crossings for quiet zones to when a quiet zone is established.

FRA related Items specifically related to FRA and FRA’s role in the quiet zone process.

Guidance or assistance Items that are related to guidance available, or could be made available, and 

technical assistance available, or could be made available, to stakeholders in 

the quiet zone process.

Safety/risk Items related to safety of quiet zones, or risks associated with quiet zones. 

This includes mentions of liability or risk issues, liability insurance, reliability of 

safety devices, uniqueness or special characteristics of crossings, and similar 

items.

Other Catch-all category that includes items not related to other challenges.

No challenge Includes stakeholders that said establishing a quiet zone was not a challenge, 

or that did not mention any challenges.

Improvements

Funding/cost Items related to funding quiet zones or reducing or controlling costs of quiet 

zones or the process of establishing quiet zones.

Process related Items related to the change or improvement of the process for establishing 

quiet zones. Includes such things as requiring diagnostic reviews and 

extending Notice of Quiet Zone Establishment period beyond 21 days.

FRA related Items related to changes or improvements that FRA can make related to the 

process of establishing quiet zones or overseeing/monitoring quiet zones. 

Includes such things as expediting FRA reviews and requiring FRA oversight 

or inspections of quiet zones 

Guidance or assistance Changes or improvements that relate to guidance or assistance related to the 

quiet zone process.

Safety/risk Items related to the safety or risk of quiet zones. Includes such things as 

considering pedestrians and pedestrian safety and requiring SSMs at all grade 

crossings.

Other Catch-all category that includes items not related to other categories.

No improvements Includes organizations that said no improvements are needed or who offered 

no improvements.

Source: GAO. | GAO-18-97

To further enhance our understanding of quiet zone challenges and 

improvements, we reviewed guidance issued by FRA about quiet zones 

and the train horn rule. This included FRA’s How to Create a Quiet Zone 

document (posted to the FRA website in September 2012) and FRA’s 
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-18-97 Railroad Safety

user guide about quiet zones published in September 2013.14

Additionally, we reviewed FRA’s regulations governing train horns and 

quiet zones. We also interviewed FRA program officials about the quiet 

zone process, application processing, various aspects of the train horn 

rule, and obtained information from FRA about quiet zone guidance.

To determine how FRA is evaluating the effectiveness of the federal train 

horn regulations, we reviewed FRA’s analysis of the safety of quiet zones 

at highway-rail-grade crossings completed in 2011 and 2013, which 

compared the safety of grade crossings in quiet zones to the safety of 

grade crossings where the train horn is sounded. We also discussed with 

FRA program officials the methodologies used to prepare these studies, 

and concerns with the data, conclusions, and plans to conduct future 

analyses. To assess the reliability and methodological soundness of the 

studies, we used the same approach as above. Both analyses were 

reviewed by a statistician and economist to corroborate the review. In 

addition to developing criteria for reviewing the analyses, we also 

reviewed guidance by FRA and others regarding analyzing incident data 

at grade crossings and about the limitations of a paired t-test—FRA’s 

methodology for comparing the grade crossings.15

To assess the extent to which FRA’s methodology generally reflects

internal control principles, we reviewed it against practices for presenting 

accurate information and communicating with internal and external 

stakeholders outlined in the Standards for Internal Control in the Federal 

Government.16 We also conducted data reliability assessments with 

respect to the underlying data FRA used in its analyses. FRA’s analyses 

used data that originated from two distinct FRA databases: ccmMercury 

(CCM) and the Safety Data Analysis website. CCM is a correspondence 

management system which includes all data on quiet zones—such as the 

establishment date and grade crossings included, among others. This 

information is contained in the Notice of Quiet Zone Establishment that 

the public authority establishing the quiet zone is required to provide to 

 14FRA, How to Create a Quiet Zone (posted online September 27, 2012), and Guide to 

the Establishment of Quiet Zones: An Information Guide (Washington, D.C.: September 

2013).

15A paired t-test is a statistical method used to compare two population means where 

observations in one population can be paired with observations in the other population. 

16GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-18-97 Railroad Safety

FRA. Alternatively, the Safety Data Analysis website contains two 

datasets: the Grade Crossing Inventory System (GCIS) and the Railroad 

Accident/Incident Reporting System (RAIRS). The GCIS contains 

information on every crossing in the nation and was used to identify the 

characteristics of the individual crossings within the quiet zone, whereas 

the RAIRS contains details about each crossing collision incident that has 

occurred. To assess the reliability of the data used in our review, we 

examined FRA reports, reviewed prior GAO data reliability material, and 

interviewed FRA stakeholders about how the data were collected, stored, 

and used. We determined that the data were sufficiently reliable for the 

purposes of our objectives.

Finally, to understand how FRA conducts oversight of quiet zones, we 

interviewed FRA program officials about oversight of quiet zones, 

guidance to staff and public authorities, and any planned changes for how 

the agency conducts oversight of quiet zones. We also interviewed GCMs 

in each of FRA’s eight regions to understand how they carry out oversight 

of quiet zones and to learn about the extent to which differences exist 

across regions. We also reviewed prior GAO reports that summarized 

FRA’s oversight approach to the rail industry, including its more traditional 

inspection disciplines. We also asked stakeholders included in our 

sample of FRA GCMs, states, public authorities, railroads, and private 

industry consultants about the challenges of establishing quiet zones and 

potential improvements to the quiet zone process. We then assessed 

FRA’s oversight approach using the Standards for Internal Control in the 

Federal Government.

We conducted this performance audit from July 2016 to October 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Transportation

Page 41 GAO-18-97 Railroad Safety

Appendix II: Comments from the Department 

of Transportation
Appendix II: Comments from the Department 

of Transportation

Page 42 GAO-18-97 Railroad Safety
Appendix III: List of Organizations Contacted 

by GAO

Page 43 GAO-18-97 Railroad Safety

Table 3: List of Organizations Contacted by GAO

Name of organization Type of organization 

Federal government

FRA Headquarters Federal government

FRA Region 1 Federal government

FRA Region 2 Federal government

FRA Region 3 Federal government

FRA Region 4 Federal government

FRA Region 5 Federal government

FRA Region 6 Federal government

FRA Region 7 Federal government

FRA Region 8 Federal government

The Volpe National Transportation Systems Center Federal government

FHWA headquarters Federal government

State agencies

California Public Utilities Commission State agency

Colorado Public Utilities Commission State agency

Illinois Commerce Commission State agency

Illinois Department of Transportation State agency

Maryland State Highway Administration State agency

Texas Department of Transportation State agency

Local organizations

Broward County Metropolitan Planning Organization, Florida Local government

City of Richmond, California Local government

City of Rocklin, California Local government

City of Commerce City, Colorado Local government

City of Fort Collins, Colorado Local government

City of Windsor, Colorado Local government

Denver Regional Transportation District, Colorado Local government

City of Baldwin, Florida Local government

City of Galesburg, Illinois Local government

City of Oak Lawn, Illinois Local government

Montgomery County Department of Transportation, Maryland Local government

City of Aledo, Texas Local government

City of Fort Worth, Texas Local government

Railroads

BNSF Railroad 

Appendix III: List of Organizations Contacted 

by GAO
Appendix III: List of Organizations Contacted 

by GAO

Page 44 GAO-18-97 Railroad Safety

Canadian National Railway Railroad 

Canadian Pacific Railroad Railroad 

CSX, Inc. Railroad 

Florida East Coast Railway Railroad 

Kansas City Southern, Inc. Railroad

Norfolk Southern Railroad Railroad 

Union Pacific Railroad Railroad 

Private industry consultants

CTC, Inc. Consulting firm 

Felsburg Holt & Ullevig Consulting firm 

Quiet Zone Technologies, Inc. Consulting firm 

Robinson Engineering Consulting firm 

SRF Consulting, Inc. Consulting firm 

Associations

American Short Line and Regional Railroad Association Trade association

Association of American Railroads Trade association

National Railroad Construction and Maintenance Association Trade association 

Others

David E Clark (Marquette University) Academic

Source: GAO. | GAO-18-97
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 45 GAO-18-97 Railroad Safety

Susan A. Fleming, (202) 512-2834, flemings@gao.gov

In addition to the contact named above, Susan Zimmerman (Assistant 

Director), Krister Friday, Sarah Gilliland, Timothy Guinane, Richard 

Jorgenson, SaraAnn Moessbauer, Malika Rice, Amy Rosewarne, Melissa 

Swearingen, Larry Thomas, and Crystal Wesco made significant 

contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101022)
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