Sort of. The official process comes in a couple different flavors, and there are absolutely ways to game it. It's not like EPA is running the tests themselves

Sort of. The official process comes in a couple different flavors, and there are absolutely ways to game it. It's not like EPA is running the tests themselves, they just write the rules. Also, AFAICT there is no penalty for sandbagging (see also Porsche). Tesla could give realistic numbers but instead ran the tests in the most optimistic way possible and chose the best numbers they could plausibly claim to be EPA formula.