If anyone wants to fight this, you really need to go about it systematically. The first place to start has to be
the written warranty for the battery. Which is this (with a bunch of capacity and fire stuff removed):
Notice the warranty specifically covers the battery
UNIT. In fact, the warranty on the battery is void if you service or open the
UNIT. Which you have to do to replace the PCS. (Side note, pretty funny Tesla tells you ignoring warnings can cause denial of warranty, yet they hide the PCS warning from you so you won't notice you have something that needs to be repaired under warranty)
Now let's look at how Tesla tracks the "battery" in their own parts catalog:
View attachment 907118
It's a battery "assembly." It is not possible to buy a battery without buying the PCS- notice how the batteries carry terms like 1PH - that means 1 phase, which is defined by the PCS inside. So if Tesla does replace the battery under warranty, they
will replace the PCS. But if the PCS fails, that's not part of the battery warranty? That's some circular logic.
But wait, doesn't Tesla sell the PCS individually? Yes, they do. And in their catalog, it's specifically under the category called "HV battery electrical
COMPONENTS"
View attachment 907123
Which makes the PCS clearly a component of the battery, yet the warranty covers the battery
UNIT, which any reasonable person would consider to be a group or components. There are a bunch of components in there that would completely prevent the car from working- like contactors, busbars, and fuses. Is Tesla going to argue that if a contactor fails, that's not part of the battery either because it's in the penthouse? What if the PCS fails in a way that it causes the whole car to shutdown, such as a 12V DC/DC conversion failure?
So- Tesla won't sell a battery without a PCS inside, yet according to Tesla it is not part of the battery "unit"? And if you want to repair the PCS yourself, you must open the battery- which voids your battery warranty. Which means only Tesla can service your car to maintain your warranty, which would be illegal under the Moss-Magnuson act. An yes, Tesla considers the penthouse part of the battery, the cover for the penthouse is literally listed as a HV battery component:
View attachment 907124
This seems like a clear slam dunk if you took it to any court with a well laid out set of facts- and all you need to do that is Tesla's own published warranty and their parts catalog to prove they are denying you coverage on something they themselves internally define as an assembly. Is Tesla really going to succeed at convincing a court that a battery assembly is different from a battery unit? Especially with
Contra proferentem- which means that when contract terms are ambiguous, courts find against the author of the contract.
I hope that people that do get charged for a PCS that is supposedly not under warranty take this to Small Claims or arbitration.