Shares sold short in Tesla Motors Inc. (NASDAQ: TSLA) moved up 8% to 31 million in the period that ended June 30. The news of the increase was overshadowed by the fact that the interest is a huge 28% of its float.

Shorts have strong reasons to accumulate positions. Shares have dropped from a 52-week high of $286.65 to about $224.

There are three things at the heart of skepticism about Tesla. The first is that deliveries of cars have lagged expectations and may well continue to do so. Founder Elon Musk says deliveries are slow because factory capacity is not yet ready for a surge of orders. That is very bad news, particularly since there is a backlog of over 400,000 orders of the new Model X, which is priced well below other models at $35,000.

Additionally, the slow delivery may mean Musk’s goal of delivering 500,000 cars a year toward the end of this decade is at risk. His massive Gigafactory will need to be online soon. Musk has a habit of missing dates.

Next, safety questions about the autopilot feature on Tesla cars have emerged because of one fatal accident involving a car in which the feature was turned on. There have been two others, but not fatal ones. Autopilot has been pushed by Tesla as one of its most important features, as every major car company in the world, as well as Google, has pressed into the same market.

Finally, Musk’s efforts to take over SolarCity Corp. (NASDAQ: SCTY), in which he and several of his associates are shareholders, has raised questions about whether Musk looks out for his shareholders or himself.

Taken as a whole, all these negatives are enough to support large short positions.

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