I think your looking at EPA the wrong way. On an ICE it's also rarely achievable same as Tesla. Your EPA ratings on both an ICE and Tesla is static because it's based on a defined testing procedure. In other words you CAN reach it but conditions have to be the same or similar to what EPA used. A more realistic metric is to use expected range (which is based on your driving style and conditions) or what @Boatguy suggests.
My old Buick got about 2 mpg below the EPA rating when I was doing a lot of in town driving, but then I also lived on hills. On the highway through it consistently got the EPA rated mpg, it didn't seem to matter how fast I was driving either.
Tesla knows the shape of the curve, location of the median, standard deviation, etc. etc. Why not publish EPA and median with a description of how the median driver drives since Tesla knows their average speed, mix of freeway versus local, etc.?
If M3 owners get 13% less than the EPA number, there is going to be an uproar. It's in Tesla's interest to be as transparent as possible.
We know the S90D EPA number is 273 W/mi. I'll start a poll and see what the curve looks like. We'll let the numbers do the talking.
Here is the poll.
Nobody else in the car industry publishes EPA gas mileage and their own numbers.
I've found that how you drive and conditions affect range in EVs much more than in ICEs. It's the efficiency, when driving a car that is capable of 90% efficiency, everything will reduce your efficiency, but driving a car that is only 20% efficient under most conditions, environment will have less impact on the overall range.
I've gotten pretty close to rated range in my S. I don't see it in town, but I have on some short roadtrips range within 1-2 miles of the rated range.