No matter what your definition of Pay to Win is, the 50% reduction to Orange mod cooldowns available to Premium players is straight up Pay2win.
It is a clear cut advantage that you are unable to earn in any way that isn't purchasing a Premium subscription
This issue was brought up multiple times and seemingly swept under the rug. It would be nice to see an otherwise fair game lose its only true pay to win feature.
Wheter everyone should get 50% off cooldowns or the cooldowns should stay the same is not the point of this thread.