Payload penalties due to the extra weight of battery systems are often not included in the total cost of ownership (TCO), particularly in optimistic studies that claim only a small fraction of long-haul trucks will experience reductions in cargo capacity. Few other studies explicitly include payload losses in TCO calculations. For example, Nykvist and Olsson 15 computed the cost components on a per ton-kilometer basis to account for differences in transported loads between a diesel truck and a BET with the same total vehicle weight. However, their analysis considers individual trucks in isolation which is likely overestimating the payload penalty given that a significant portion of long-haul trucks are not mass-limited. Approaches for estimating payload penalties that explicitly account for payload distributions in U.S. long-haul trucking would provide a more accurate and realistic estimate of the impact of battery weight on TCO, but they are lacking in the literature.