It depends in the phone is able to still periodically power on the cell radio, but I guess that will be spotted during the fcc test. Other than that, the only way to track a device is if you are very close and it has some kind of RFID, or something else that can respond to RF without having a local power source. Most cities have a wide range of RFID trackers for collecting traffic data, though there is nothing saying that they cannot track other things that can respond to a similar fashion to RFID
PS modern smartphones never fully power off, if you run it through a multimeter, you will see that even when powered off, they will pull quite a few microamps (though it may be for the soft power switch, clock and other needed components to listen for that button press)