Orange EV appreciates being included in the “Global Electric Trucks and Delivery Vans Markets Report for 2018-2028”, even if wrongly classified.  In the report, Orange EV is incorrectly categorized as a medium-duty electric vehicle (MDV). By all standards, terminal trucks (aka yard trucks, hostlers, spotters) are heavy-duty electric vehicles (HDV).  According to the Federal Highway Administration, a heavy-duty vehicle has a GVWR >26,001 pounds, and a Class 8 heavy-duty vehicle has a GVWR >33,001 pounds. Orange EV 100% electric trucks have a GVWR of 40,900 pounds and are therefore Class 8 heavy-duty vehicles. Building both new and re-powered terminal trucks, [...]