That runs at odds with a claim made on Tesla's site: "The Model S battery will not lose a significant amount of charge when parked for long periods of time. For example, Model S owners can park at the airport without plugging in."
Either Tesla is lying when it claims that it won't lose a significant amount of charge, or Tesla is not lying (which would imply that not charging overnight doesn't really matter)
But this also doesn't say that you can expect to lose 65 mile range in the cold if it's not plugged in. This is very good information to know and not at all what's implied by the link you provide, but it would have been good if the article had discussed all this in full context.
"... The Tesla battery is optimized for nightly charging: topping off frequently enhances the longevity of your battery."
So though I agree that the author has a good argument he should have mentioned that Tesla does advise nightly charging albeit for battery maintenance rather than to guard against charge loss.