The batteries in the first 2012 cars needed thorough testing, so they are 2010/2011 tech. Three or four years later would be ... right about now!
Also, Occam's Razor works both ways here. We know that new cell tech WILL inevitably supersede the old one and it must be tested, too. So what better way to do this than in the car with, most likely, the lowest sales numbers, and thus teh lowest risk in case of a recall, in the Model S line-up? The 400 mile roadster is already a good indication of what to expect. To me it seems perfectly logical that they would try out the new cells in the roadster first, then take it one step further and ramp up production with the 70D.