like "daox" said,
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hybrids are a different story
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because as they come out of the factory they are mechanically & aerodynamically enhanced for FE which means IMHO it would take more effort and innovation to improve the MPG figures over the ones measured by EPA for example. Things like regenerative braking, start/stop , use of electric motor at low speeds help keep the FE high, whilst when driving a regular car using hypermiling techniques there's more things to improve simply because "regular driving" is bad for FE.
Just my 2¢