This caught my attention: “....Although the DOT has plans to replace the DOT-111’s,...”
So the DOT owns these railcars, and is going to replace them eh. NOT. These cars are owned by private enterprise, and the government is going to coerce private enterprise to replace them with something certainly more costly, and perhaps less efficient if it is to Liberal standards.
More than likely the cars are owned by Warren Buffet, but then still it’s private enterprise isn’t it.
The older DOT-111 tank design was criticized for decades and the design was changed (made stronger) Oct 2011. There was no plan until recently to force phase out of the existing railcars already built under the old design.
In November 2013, the Association of American Railroads again urged PHMSA increase federal tank car safety by requiring all tank cars used to transport flammable liquids be built to a higher standard, and all existing cars to be retrofitted to this higher standard or phased out of flammable service.
https://www.aar.org/safety/Documents/Railroad%20Tank%20Cars.pdf
Most of the oil tanker railcars are not owned by the railroads. They are owned by oil/refinery companies who hire the railroads to move the cars.