I thought I read on EPA test website that they use a custom fuel blended just for EPA, along the lines of 93 octane, no ethanol? Have to double check, but that would be a factor as well, testing versus real world.
Maybe list the type of fuel used on the car sticker, with big font words about E10 and lower octanes WILL reduce your MPG?
I could be way off, but fuel type used could be a part of these discrepancies?
__________________
|