I agree it's a distinction that is important - but again I was being specific about that Nevertheless wind effects are relevant.
Yes if it's a cloudy day with no temperature changes, after 8 hours it probably doesn't matter if there was wind. But it was a sunny day and then the temperature drops (not uncommon when the sun goes down) then wind can still have a significant impact on the final pack temperature.
If you are parking for a shorter period of time, then wind has an immense impact. If you park for an hour on a cold but sunny and calm day, you'll have a mild regen limit. If you park for an hour in the same conditions but with strong winds, you could have no regen and a power limit. The pack has a LOT of exposed area underneath. That's why the Roadster stays warmer longer; its box-like battery pack has much less exposed area for its volume.
I've found that in extreme cold (-20C and below) the battery pack never reaches normal operating temperatures, even after hours of driving on the highway. The cooling slipstream under the car still chills out the pack. I've driven on the highway for over two hours, then parked and had the car immediately pop the warning about plugging in because the pack is cold.