[Spoiler Alert + Mild Speculation] Tesla has created a monster!

[omgwtfbyobbq]

That's a reasonable argument when you look at the EPA rules but I don't think it's true. For example, the Model S P85D has its own EPA test and they used the 19" wheels. This example shows that Tesla can use the smaller wheels for range tests even if most sales of that model are with the larger wheels.

I can think of two counter arguments:
#1. Maybe less than a third of Model S P85D's are configured with 21" wheels.
#2. Maybe the P85D achieved 253 miles EPA rated range with 21" wheels.

#1 is unrealistic so I'm going to skip that. #2 is not true based on 3 data points:

1. In the footnote here says "In the table above all vehicles... " use 19" wheels.

2. If you read the blog post, it says that the 253 miles number will get a 3% hit with 21" wheels. Here is the relevant section:


3. The P85D initially had 242 miles EPA rated range (see the first screenshot). This was achieved using 21" wheels (see the second screenshot). However, then they changed it to 250 mi with 19" wheels and then to 253 miles.

I agree with you that according to the EPA rules, it should work how you have described it but I disagree that this is what actually happens. Here is the rule again:


Based on this, performance versions like the P85D and P100D should have the 21" factor accounted for in calculations but it doesn't appear to be the case. One counter argument at this point could be that maybe Tesla uses the voluntary reductions to make things right. Yes but in the last 2 years Tesla voluntarily lowered the EPA range of 7 different cars and all of them were Model S variants. None of them were Model X. In other words, they have been using voluntary reductions to reduce the gap between the S and X. Now they are using it for the Model 3 too.

I'm not sure how useful the EPA ratings are, since those are submitted by the manufacturer and can and have been under reported. Tesla can rate their cars however they want to, as long as they don't inflate their ratings, like any other manufacturer, but the figures from the CSI report have to conform with EPA regulations.

The CSI report shows that Tesla used a road coefficient of 12.3 for the P85D and 11.9 for the 85D, which suggests they were using the 21" wheels for the P85D.

https://iaspub.epa.gov/otaqpub/display_file.jsp?docid=34294&flag=1

Last but not least, Tesla's application for the P85D explicitly states they're using the "worse case for emissions", and lists 21" wheels/tires.

https://iaspub.epa.gov/otaqpub/display_file.jsp?docid=34511&flag=1

Data Vehicle Selection Justification – This vehicle represents the 33% optioned test weight class, highest total road load, and highest N/V ratio that are expected to be the worst case for emissions.

Tires 245/35R21 (Front) 265/35R21 (Rear)

Tesla could be using the 18" wheels for the 3 LR, and we'll only know when the EPA publishes their application (or maybe the CSI report for the 3 SR), but my guess is the CSI report they submitted is with the 19" wheels.

 

[omgwtfbyobbq]

For what it's worth, the P100D (469.99 miles) also has better results on the HWFET than the 100D (449.76 miles).

https://iaspub.epa.gov/otaqpub/display_file.jsp?docid=39795&flag=1

Tesla broke up the 2017 Model S line into two subconfigurations as well, and I'm not sure which subconfiguration is being used in the EPA ratings.

https://iaspub.epa.gov/otaqpub/display_file.jsp?docid=38161&flag=1

I'm guessing Tesla could break up the 3 into multiple subconfigurations as well, although I'm not sure which one the EPA ratings would be based on.

Edit - The road load target coefficients from the 19" wheel configuration in the application match up with the CSI target coefficients, so Tesla's using the 19" wheels on their submission data. I imagine they could do the same with the 3 if they have a configuration and sub-configuration.

 

[Troy]

@omgwtfbyobbq,

Can you add more commentary to your messages? I see some sources but I don't understand what you are trying to say. This is the discussion so far:

My argument: The Model 3 80 scored 334 mi EPA but Tesla voluntarily lowered it to 310 miles to make the Model S look good.
Your argument: Maybe they lowered it to 310 because of the wheels.
My argument: No, Tesla doesn't do that. They advertise the range number with the smaller wheels even for the performance cars.
Your argument: According to the rules Tesla has to show the range with larger wheels if more than a third of that model is sold with larger wheels.
My argument: Yes but Tesla has already confirmed multiple times that 253 mi EPA for the P85D is with 19" wheels and 242 mi EPA was with 21" wheels.
Your argument: ... unknown

You said the following:

The CSI report shows that Tesla used a road coefficient of 12.3 for the P85D and 11.9 for the 85D, which suggests they were using the 21" wheels for the P85D.

Yes but that only confirms they have done an EPA test for the P85D with 21 wheels. We already knew that because Tesla has already confirmed that the 242 mi result was with 21" wheels and the 250 mi number was with 19" wheels which they have later improved to 253 mi. Here is the situation:

P85D= 253 mi EPA with 19" wheels
P85D= 242 mi EPA with 21" wheels
See these sources: Window sticker, Design Studio, Blog footnote, Blog text

For what it's worth, the P100D (469.99 miles) also has better results on the HWFET than the 100D (449.76 miles).

Again please add more commentary. I don't understand why you wrote that. We have already talked about it in last few messages here. It appears to be a fluke because the same problem didn't happen with any of the other three P versions.

Edit - The road load target coefficients from the 19" wheel configuration in the application match up with the CSI target coefficients, so Tesla's using the 19" wheels on their submission data. I imagine they could do the same with the 3 if they have a configuration and sub-configuration.

I don't understand what car you are talking about or what conclusion you are drawing about what car from what source. Are you saying here that you were wrong about your earlier 21" assumption? The 19" exists both on the Model S and Model 3. Can you phrase your arguments clearer and integrate your sources to your sentences better?

 

[omgwtfbyobbq]

I gotcha. Those aren't my arguments. The points I tried to make were....

• It's difficult to come up with accurate range comparisons using Tesla's EPA ratings because Tesla can unilaterally and arbitrarily lower those ratings.
• If Tesla only has one configuration for the 3 LR application, like they did with the P85D, they likely had to use the 19" Sport for the same reason they had to use the 21" wheels for the P85D.
• If Tesla has two subconfigurations for the 3 LR application, they likely could use the 18" Aero wheels.

My feeling is the most accurate comparison between vehicles is using the CSI report data. If that isn't available for some subconfigurations, it should be possible to estimate the range by simulating the test with the road load values and EPA trace for each test.

 

[Troy]

Hi, @omgwtfbyobbq.

It's difficult to come up with accurate range comparisons using Tesla's EPA ratings ... My feeling is the most accurate comparison between vehicles is using the CSI report data.

I agree which is why I have used the dyno highway scores in my comparison here and not the EPA rated range numbers. The orange cells are calculated from the dyno highway scores on the left under the column HWFET highway range. Because I'm already using the dyno score and not the EPA rated range, I don't understand why the comment was necessary.

I'm trying, but I don't understand the other two comments either.

• If Tesla only has one configuration for the 3 LR [as in 80/80D/P80D or as in 18"/19"?] application, like they did with the P85D [what do you mean?], they likely had to use the 19" Sport [in which car? P85D or Model 3?] for the same reason they had to use the 21" wheels for the P85D [which they did not do as confirmed by Tesla. So why are you saying they used 21" wheels for P85D EPA when Tesla confirmed multiple times they used 19" wheels for the 250 mi score?].
• If Tesla has two subconfigurations for the 3 LR [as in 80/80D/P80D or as in 18"/19"?] application, they likely could use the 18" Aero wheels.

Also, I don't understand how these are related to an EPA test that is already completed and scored 334 miles and voluntarily lowered by Tesla to 310 miles.

 

[Troy]

Let me try to add more structure to the discussions:

The Facts:

1. The Model 3 80 (aka Model 3 Long Range RWD) scored 334 miles in the EPA test as confirmed by MPGe and energy consumption numbers.
2. Tesla voluntarily lowered Model 3 80's EPA rated range from 334 miles to 310 miles.
3. In the last two years, Tesla voluntarily lowered EPA rated range numbers 7 times for the Model S but never for the Model X.
4. To achieve the 334 miles EPA rated range with the Model S 80, Tesla used the 0.7 multiplier to convert dyno scores to city and highway range numbers.
5. Almost all EV manufacturers use the 0.7 multiplier but Tesla has never used it before the Model 3. They have always used higher multipliers for all Model S and X variants.
6. In EPA highway dyno tests, the Model 3 80 achieved 454.64 miles and the Model S 100D 455.37 miles.
7. Tesla used 19" wheels to achieve 253 miles EPA rated range for the Model S P85D.

I don't mind talking about these and going over the data again.

My speculation:

1. Tesla voluntarily lowered the Model S EPA rated range numbers to make the range gap between Model S and Model X look smaller.
2. Tesla voluntarily lowered the Model 3 EPA rated range numbers to avoid the Model 3 exceeding Model S' range.
3. The Model 3 80 will match the Model S 100D's highway range in actual road tests.
4. The Model 3 80D will exceed the Model S 100D's highway range in actual road tests.

 

[arg]

• Tesla voluntarily lowered the Model S EPA rated range numbers to make the range gap between Model S and Model X look smaller.

• Tesla voluntarily lowered the Model 3 EPA rated range numbers to avoid the Model 3 exceeding Model S' range.

Another possible motivation: Tesla want the EPA number to be "you can fairly easily get this in real life if you drive conservatively", and as you pointed out upthread, the only range number EV drivers really care about is on long trips that are mostly highway.

So with Model3 doing particularly well in town, maybe they felt that the resulting number was too optimistic and didn't want to put out a sky-high EPA number only to get people complaining you couldn't achieve that number in real use?

I'm not sure how the Model X vs Model S comparison works out: with the (fudged) numbers, is it about equally easy to achieve EPA on the two cars?

 

[omgwtfbyobbq]

Let me try to add more structure to the discussions:

The Facts:

1. The Model 3 80 (aka Model 3 Long Range RWD) scored 334 miles in the EPA test as confirmed by MPGe and energy consumption numbers.
2. Tesla voluntarily lowered Model 3 80's EPA rated range from 334 miles to 310 miles.
3. In the last two years, Tesla voluntarily lowered EPA rated range numbers 7 times for the Model S but never for the Model X.
4. To achieve the 334 miles EPA rated range with the Model S 80, Tesla used the 0.7 multiplier to convert dyno scores to city and highway range numbers.
5. Almost all EV manufacturers use the 0.7 multiplier but Tesla has never used it before the Model 3. They have always used higher multipliers for all Model S and X variants.
6. In EPA highway dyno tests, the Model 3 80 achieved 454.64 miles and the Model S 100D 455.37 miles.
7. Tesla used 19" wheels to achieve 253 miles EPA rated range for the Model S P85D.

I don't mind talking about these and going over the data again.

My speculation:

1. Tesla voluntarily lowered the Model S EPA rated range numbers to make the range gap between Model S and Model X look smaller.
2. Tesla voluntarily lowered the Model 3 EPA rated range numbers to avoid the Model 3 exceeding Model S' range.
3. The Model 3 80 will match the Model S 100D's highway range in actual road tests.
4. The Model 3 80D will exceed the Model S 100D's highway range in actual road tests.

I'm not strictly speaking disagreeing with anything, but I think there are some pieces that should be added or changed.

Using the UDDS/HWFET scores from the CSI reports is fine for comparison. The thing is, if we can't compare the road load parameters from the application to the parameters in the CSI report, we can't know which wheel Tesla was using for the test. They've used their performance wheel at times, and the stock (more efficient) wheel other times. If the 3 LR only has one configuration, they may use the Sport wheels, ala the P85D application I have in my earlier post on this page. If they have subconfigurations in the 3 LR's application, they'll probably use the Aero wheels because that's what they did for the 2017 Model S line.

In terms of the range, if the CSI report tests were with the Aero wheels, then the values from it are the maximum range. If the report tests were with the Sport wheels, then a car with Aero wheels will do better in terms of range than the current CSI rantings, and far better than the 310 mile range estimate from Tesla. It may even do better than a P100D on the HWFET, and there's a good chance it could do better at higher speed cruises.

For the facts you referenced, I don't see a CSI report or Application where the P85D is using 19" wheels. The only one I found was with the 21" wheels (linked above). If there isn't one, it's a good idea IMO to remove it from the facts section. The only other change I would make would be to put an asterisk next to the 3 LR noting that we don't know which wheel was used during testing. Everything else I think is accurate.

 

[brianman]

Does the P100D actually get ... the same range as a P100D on the highway?

Yes. I suspect you meant to ask something different though.

 

[Troy]

Hi, @omgwtfbyobbq.

It sounds like you are not sure about fact #7.
Fact #7: Tesla used 19" wheels to achieve 253 miles EPA rated range for the Model S P85D.

Here are the data sources for fact #7 so people can see I'm not making up stuff:

Data source 1: Read the following paragraph from Tesla's blog post here.

Tesla: The 21" performance tires are a more commonly selected option on our performance variants (P85, P85D and formerly P85+) since many of these performance-oriented customers want the best possible handling. There is however roughly a 3% reduction in EPA 5-cycle range (compared to the values presented in the table above) for the selection of 21" performance tires to any of the Model S variants.

Data source 2: This footnote in the same blog post.
Data source 3: This design studio screenshot.

 

[Troy]

If the 3 LR only has one configuration, they may use the Sport wheels

Do you mean, if the EPA test that scored 310 mi, 131 MPGe city, and 120 MPGe highway efficiency is going to be the only EPA test for the Model 3 80/80D/P80D, then Tesla might have used the large wheels?

 

[transpondster]

The Model 3 80 will match the Model S 100D's highway range in actual road tests.

if you meant high speed driving my guess no. EPA highway is quite slow with stops, highway test cycle produces similar range, while S loses in city test, so real world high speed test should slightly favor S100D over 3LR

 

[omgwtfbyobbq]

Hi, @omgwtfbyobbq.

It sounds like you are not sure about fact #7.
Fact #7: Tesla used 19" wheels to achieve 253 miles EPA rated range for the Model S P85D.

Here are the data sources for fact #7 so people can see I'm not making up stuff:

Data source 1: Read the following paragraph from Tesla's blog post here.

Data source 2: This footnote in the same blog post.
Data source 3: This design studio screenshot.

Do you mean, if the EPA test that scored 310 mi, 131 MPGe city, and 120 MPGe highway efficiency is going to be the only EPA test for the Model 3 80/80D/P80D, then Tesla might have used the large wheels?

I don't disagree that Tesla rated the P85D at 253 miles of range with the 19" wheels. The ratings and the CSI report data don't have to match. Still, the CSI report they submitted to the EPA for the P85D has the 21" wheels listed. They may have submitted another CSI report for the 19" wheels that corresponds to their blog post/EPA rating, but I couldn't find it on the EPA's website.

https://iaspub.epa.gov/otaqpub/display_file.jsp?docid=34511&flag=1

They could do the same for the 3 LR, and by the same I mean use the Sport wheels for certification, and use whatever figures they want for the EPA rated range, as long as they aren't significantly overestimating the range. They could also have two subconfigurations like they did with the 2017 AWD Model S carline, but we won't know which is the case until the application is available on the EPA's website.

 

[SageBrush]

They could do the same for the 3 LR, and by the same I mean use the Sport wheels for certification, and use whatever figures they want for the EPA rated range, as long as they aren't significantly overestimating the range. They could also have two subconfigurations like they did with the 2017 AWD Model S carline, but we won't know which is the case until the application is available on the EPA's website.

Exactly.

It is also possible (though I think unlikely) that the 18" wheels were tested without the Aero hubcaps.

In any case, it keeps bugging me that I have yet to see a delivered car with 18" wheels. Could Tesla have used a sticker based on those wheels without *any* deliveries ? I know that an option that is on less than 33% of the total cars do not have to be tested but when does the 33% counting begin ?

 

[tracksyde]

In any case, it keeps bugging me that I have yet to see a delivered car with 18" wheels. Could Tesla have used a sticker based on those wheels without *any* deliveries ?

There have been a fair amount of "delivered" 3s with the 18s. Here's the last example I saw from yesterday (note the CA temporary registration in the window)

Pictures of production Model 3s

 

[Troy]

They could do the same for the 3 LR, and by the same I mean use the Sport wheels for certification, and use whatever figures they want for the EPA rated range

I don't think Tesla would ever pick the larger wheels to test a few different variants of a car. The Model S 85/P85/P85+ shared the same 265 miles EPA rated range achieved with the smaller wheels based on the blog post. P85D's 253 was also with smaller wheels. You are supporting an argument that contradicts what we have seen so far from Tesla which is, they will try to find any loophole possible to advertise even the performance cars with the smaller wheels even if almost none of those performance models are sold with the smaller wheels and even if the performance models have their own EPA rating.

Yet, you are arguing that Tesla might test the non-performance cars like Model 3 80/80D with the larger wheels. Why would they do that? That would be the opposite of what they have done so far.

Level 1: Test performance cars with smaller wheels. << Tesla is here
Level 2: Test performance cars with larger wheels.
Level 3: Test non-performance cars with larger wheels. << Your argument is here

People don't like paying more for less range. Therefore it is better for Tesla to try to make the range penalty look as small as possible for the performance versions. Anyway, here is some more data about the 253 mi EPA rated range. See 7.5 and 7.6.

7.1. Tesla said P85D's 253 miles EPA score was achieved with 19" wheels. Source1, Source2
7.2. Tesla said P85D's EPA score is 242 miles with 21 wheels and 250 miles with 19" wheels. Source
7.3. You have found an EPA document that shows 242 miles on page 8 here.
7.4. You could not find an EPA document that shows 253 miles.
7.5. The EPA page here shows 253 miles for the P85D.
7.6. There are two EPA documents that have the following data about the P85D. Switch to the "EV" tab in Excel.
2014 file, Range: 242 miles (cell FI49), EPA FE Label Dataset ID: 17473 (cell BV49), Release Date: 05 Dec 2014 (cell BU49)
2015 file, Range: 253 miles (cell FJ53), EPA FE Label Dataset ID: 17500 (cell BW53), Release Date: 01 Jan 2015 (cell BV53)

 

[omgwtfbyobbq]

I don't think Tesla would ever pick the larger wheels to test a few different variants of a car. The Model S 85/P85/P85+ shared the same 265 miles EPA rated range achieved with the smaller wheels based on the blog post. P85D's 253 was also with smaller wheels. You are supporting an argument that contradicts what we have seen so far from Tesla which is, they will try to find any loophole possible to advertise even the performance cars with the smaller wheels even if almost none of those performance models are sold with the smaller wheels and even if the performance models have their own EPA rating.

Yet, you are arguing that Tesla might test the non-performance cars like Model 3 80/80D with the larger wheels. Why would they do that? That would be the opposite of what they have done so far. Anyway, here is some more data about the 253 mi EPA rated range. See 7.5 and 7.6.

7.1. Tesla said P85D's 253 miles EPA score was achieved with 19" wheels. Source1, Source2
7.2. Tesla said P85D's EPA score is 242 miles with 21 wheels and 250 miles with 19" wheels. Source
7.3. You have found an EPA document that shows 242 miles on page 8 here.
7.4. You could not find an EPA document that shows 253 miles.
7.5. The EPA page here shows 253 miles for the P85D.
7.6. There are two EPA documents that have the following data about the P85D. Switch to the "EV" tab in Excel.
2014 file, Range: 242 miles (cell FI49), EPA FE Label Dataset ID: 17473 (cell BV49), Release Date: 05 Dec 2014 (cell BU49)
2015 file, Range: 253 miles (cell FJ53), EPA FE Label Dataset ID: 17500 (cell BW53), Release Date: 01 Jan 2015 (cell BV53)

I think Tesla, or any manufacturer, has to pick the larger wheels when vehicles sold with them have a take rate > 33% of the entire vehicle line. With the AWD Model S line, they can count every AWD Model S sold as being part of the same vehicle line, and in that comparison, even if every P90D/P100D comes with 21" wheels, my guess is the 21" wheels are present on less than 33% of AWD sales because the 60D, 75D, 90D, and 100D are also included in that vehicle line, and I imagine most of those are purchased with 19" wheels.

When the P85D first came out (2014), Tesla didn't have any other AWD models. If customers purchased more than 33% of P85Ds with 21" wheels, which I'm guessing they did, then Tesla had to use 21" wheels in the CSI report, which their application shows.

Deliveries of the P85D started in December 2014, with the 85D models starting in February 2015, and the 70D models starting in April 2015

Tesla Model S - Wikipedia

Once Tesla started delivering enough P85D, 85D, and 75D vehicles, and the take rate for the 21" wheels dropped below 33% for that entire vehicle line, which is all three of those configurations, I'm guessing they were able to use the 19" wheels for the EPA tests.

The Model 3 LR will be the only highest volume version of the 3 offered in 2017 according to Tesla, just like the P85D was the only AWD Model S offered in 2014. If the take rate for the Sport wheels is > 33%, then Tesla will have to use those in the CSI report, just like they had to use the 21" wheels in the initial CSI report for the P85D. Once Tesla starts building the Model 3 SR, and fewer than 33% of all 3 LR/SR vehicles are sold with Sport wheels, then Tesla can use the Aero wheels for the 3's CSI report, just like they did for the P85D once enough P85D/85D/70D cars were being sold with 19" wheels. They can also use the Aero wheel if they can somehow limit Sport wheel sales to < 33% of all 3 LR sales in 2017.

 

[run-the-joules]

The Model 3 LR will be the only version of the 3 offered in 2017 according to Tesla

This is false.

Which future options will be made available to order, and when?
We are planning to introduce the following options in the coming months:

Fall 2017: White interior option, standard configuration (non-Premium Upgrades)
November 2017: Standard Battery, $35,000 car
Spring 2018: Dual Motor All-Wheel Drive

Additional options will become available over time.

 

[omgwtfbyobbq]

This is false.

So they're delivering $35,000 Model 3s in 2017? They'll hopefully be available for order in November, but I don't see where it says they'll be delivering/selling them in November/December.

 

[run-the-joules]

So they're delivering $35,000 Model 3s in 2017? They'll hopefully be available for order in November, but I don't see where it says they'll be delivering/selling them in November/December.

We'll see how it works out. The same page says the non-premium interior will be available in "Fall" and a production/customer unit has already been spotted. My delivery estimator seems to be two months behind employees and says February-April if I wanted the gimpy battery, so it stands to reason some of them are showing December-Feb.