1) EPA consumption/range numbers are NOT guarantees of consumption /range for every driving condiiton. EPA consumption/range numbers are weighted averages which include SOME cold weather driving (20˚F), but more than 80% of the driving cycles are at 75˚F. These driving cycles and calculations are enshrined in law, and are the same for all manufacturers, and not an Elon or Tesla invention.
2) Consumption at low temperatures is for sure going to be higher for a number of reasons, for every car, but more so for very efficient cars, like EVs (and hybrids).
3) The amount of consumption increase is highly dependent on temperature, road conditions (like plowing through snowy/slushy/slippery roads), heater settings, etc. I have seen temporary consumption on my 2018 Model 3 as high as 400Wh/km under severe conditions.
4) Expecting a single EPA number (NOT Elon's number, by the way) to apply in every weather condition, road condition, speed, etc. is just a gross misunderstanding of the EPA consumption/range number and the meaning of a "weighted average".
Other commentaries are more kind, but ripping Elon/Tesla for following the law to measure the EPA number he didn't define, is merely trying to shift the blame of your own misunderstanding onto a third party.