It always felt like this to me but i really couldnt say.  Similarly though when my archers or casters try to fire through a hill, or when they are only halfway up the back of one, accuracy and damage seems way off.  I think elevation may have some effect as my archers on hills have always done better.  Then again, theres really no way to tell for sure is there .  Not without trawling through the game code to find out, and i'm not that tech savvy.

Now that could be tested in practice, i'll check if i ever get a battle where i have archers on a hill with enemies at 8/9/10 range (not likely to happen lol, but i'll let you know if it does).