I guess the model (as in math model, not Model S model) they use to predict energy consumption assumes 19in wheels and driving below or at the speed limit. A local P85D owner can beat the rated consumption on his car no problems in here... he tells me the trick is to never exceed ~80kW of power and drive 100kph on the highway. He also has 19in on the car with the low-rolling resistance Michelin tires.
Staying under 80kW implausible. Hills.
100kph would get me at best pulled over for driving suspiciously slow. At worst rear ended. If you do 65mph in a 55 mph zone here, people will pass you on both sides. I have the 19" wheels too.