No, you can’t. Because I might go uphill or downhill. It might rain. It might be hot or cold.
The car is doing something tricky (aka lying) as discussed above.
To the best of my understanding, this is what most modern ICE cars do when they give you the "miles remaining" metric. I don't know how else they could be so outwardly accurate.
This falls under the category of "trick", but it's actually a trick that helps me by allowing me to plan my trips better.
Giving the "current estimate of actual miles remaining", as a multi-variate function of all the things you mention, is actually less helpful and more stress-inducing – even while it's technically providing more information, it's information that isn't very helpful.
But that’s off topic; this article is about the car not meeting its EPA range, because the EPA test is very synthetic[1] and doesn’t match most people’s driving habits. I find InsideEVs’ “70 mph range test”[2] series to be far closer to my personal experience.
[1] https://www.epa.gov/greenvehicles/testing-national-vehicle-a...
[2] https://cdn.motor1.com/images/custom/bev-ievs-70mph-range-te...