Green Car Reports is carrying the story that the California New Car Dealers Association (CNCDA) has written a sharply worded letter to the California state Department of Motor Vehicles, accusing Tesla Motors of engaging “in a long-term advertising strategy to mislead consumers.” The complaint is centered on the pricing calculator featured on Tesla Motors’ website, which purports to give an “effective monthly cost” of owning a Tesla Model S. The allegedly confusing “effective monthly cost” number. Tesla Motors The CNCDA’s nine-page letter lists about a dozen specific complaints with Tesla Motors’ “True Cost of Ownership” page, most of which fall into two broad categories: savings that are calculated using outside credits or assumptions, and savings that are based on difficult-to-quantify or difficult-to-achieve metrics.

For example, the site displays a price for its vehicles that includes the $7,500 federal Plug-In Electric Drive Vehicle Credit, it adds monthly cost offsets based on the money a Model S owner will get when they eventually sell the car, and it adds monthly cost offsets based on time saved by using a carpool lane and not sitting at gas stations filling up.

The CNCDA also takes issue with the “Electricity vs. Gasoline” savings calculator. Estimated gas savings—also allegedly confusing and misleading. Tesla Motors To be sure, some of those cost offsets sound a little dubious, and it’s obviously in Tesla’s best interests to make buying a Model S as attractive as possible.

The CNCDA’s complaints don’t necessarily appear to be that Tesla is offering this information, but rather that it appears to be presenting to consumers a modified per-month cost that includes factors it deems specious—or that it believes violate automobile advertising laws. Much of the letter is concerned with calling out specific California statutes that the CNCDA alleges Tesla is violating.     

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