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Yes, Europe's rating under the WLTP test regime is still an optimistic set of figures, as the test is still representing light driving conditions.
As I see it, EV range has to be considered much the same way as ICE. We know if we drive hard, or in heavy urban conditions, we can use twice the fuel as driving light in easy conditions. To see figures like 19 - 35 miles has to be considered as a realistic range.
One area where we do lose with EV in winter, is using valuable EV range to heat the cabin. The ICE does, to a great degree, use 'waste' heat to do so. The comfort factor will show up more under EV use.
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