Don't forget about those rails. A lot of energy is locked in them, not to mention land. Planes need airports and nothing more.

Planes also spend their time where there is less wind resistance to deal with.

Trains are still a win, but it isn't as clear as it seems.

Tying up capital equipment and personnel for much less time to serve the same journey. Consider San Francisco to Chicago, a route I have done both ways. The flight is 5 hours, the train ride 50 hours. A 737 is more expensive than the California Zephyr trainset, but not by 10x.

I'm not sure what noise has to do with efficiency - I doubt that the energy expended on vibrating the air is physically or economically significant - but it is worth noting that trains are loud. Particularly because regulations written in blood require that they blow their horns three times at every level crossing at all hours.

(Among developed countries I'm familiar with) it's only the USA that has the excessively loud train horns at level crossings, and a lot of crossings. In Europe, lights, bells (or a beeper thing) and automatic barriers are used instead, sometimes with automatic or manual infrared/visible cameras to confirm the crossing is clear of road vehicles.

Point-to-point travel is much faster and more efficient with planes than with trains.