Earlier quoted context omitted.
If I were to speculate, and I am, I would guess that the variable here is the temperature of the battery packs. Batteries are chemical power sources, and the chemical reaction which frees up electrons has temperatures where it works, and temperatures where it doesn't. (Hence "cold weather amps" as a selling point on car batteries). Anyway, I'd speculate that the Tesla person was thinking that if the battery got up to…
The battery's heating system likely drained the power overnight. The battery pack must be kept above a certain temperature or it will become irreparably damaged.
Edit: This article http://electronicdesign.com/power/operating-conditions-get-t... says "permanent damage at -50 degrees C" which is way colder than the lower 48. It's a good thought though, and I'm sure if you were connected to the wall at night the car would heat the batteries to an optimal temperature. Just not sure why it might do that without power available.