Rules says:
- the track must be built low to the ground (only 3 tiles high off the ground is allowed)
If you can build a tunnel within 3 tiles above the ground, then it's allowed.
If you want to go downwards instead, you can build on the ground and within 2 tiles below the ground.
If you do choose to go downwards, you'll have to sacrifice your ability to build in those 3 tile spaces above the ground, and use only the one on the ground.
If that doesn't make sense, I'll make a screenshot.