I thought that MINI provided the parameters, and the EPA dialed in the rolling road. I read the report and the real problem is the fudge factor the EPA use. The results from certificate number LBMXV00.0F5B-027 (2020 SE) are:
city cycle miles till exhausted: 166.97
highway cycle miles till exhausted: 145.62
Average: 60% city, 40% highway: 158.43
"fudge factor": 0.7
EPA range = 158.43 * 0.7 = 110.9 miles.
So, the actual range they got was 158 miles (40% highway, 60% city). You only get the 110 figure by multiplying by the one figure fits all 0.7 . Ironically, the 158 miles fits almost perfectly with the best reported by several testers (including myself). I get 155 miles (250km), Edmunds got 150, Car wow got 154. All these are in good, maybe excellent conditions. The real issue is the dodgy correction factor. The factor is used when manufacturers only do the 2 tests (city/highway) rather than all 5 (like Tesla does). That is the main reason that Tesla is close or a little under EPA, and most European manufacturers who only do a 2 test version are significantly better (eg. Porsche Taycan, MINI etc).
I agree, it is MINI's fault for not doing all 5 tests and getting a more realistic figure. You probably find they don't care as they won't sell any more cars in the US due to the current demand outstripping supply, and Europe/UK uses the WLTP value which is far more realistic.
PS. you can get the test reports from the EPA site - I probably can't share it due to copyright etc. Search for the certificate number above. I do believe that the EPA "real" results really are best case scenario, so they really are an upper limit. To get better, you would have to hypermile, which the tests do not do.