EPA Raw MPG Data
I received the information from the EPA that I requested and thought I'd post about it. The EPA engineers were very responsive both on the phone and via email. There's probably a lot more detail here than people want, but here it goes..
The EPA requires emissions tests on vehicles and, during those tests, the fuel economy is measured. The tests involved 5 driving cycles: City(FTP75), Highway(HFET), Aggressive(US06), Air Conditioning(SC03), and Cold Temperature(FTP20) which are explained here (
https://www.fueleconomy.gov/feg/fe_test_schedules.shtml). The CX-9 measured emissions and fuel economy can be found on the 'Certificate of Summary Information' which is available on the EPA website.
https://iaspub.epa.gov/otaqpub/. The 5-cycle fuel economy values are called "unadjusted" because they are based on the dynamometer test and not real driving. As a result, the EPA downgrades the numbers to be more accurate and then weights all of the results to arrive at an expected 'city' and 'highway' fuel economy. These downgraded values are called the 'adjusted' city and highway fuel economy. The window label always shows the adjusted (downgraded) mpg values. I have plotted in blue all of the 2016 CX9 unadjusted fuel economy values based on the certificate of summary information (i.e. the raw data). The data provides insight into the relative impact of air conditioning, aggressive driving, etc. for the CX-9.
The EPA has equations to convert the unadjusted data to 'window values'. I used those equations and got lower values than the actual window label. That is what prompted my call to the EPA. After some discussion, I learned that (1) the emissions-based mpg data (blue) were
not used in the calculation of the window label, (2) the emissions-based mpg data were done on a 4WD CX-9 with sport mode turned on in order to test the worst-case emissions scenario, and (3) additional tests (red) were done on a 2WD in non-sport mode and that these tests
were used to compute the window-label values. Those (red) tests show an unadjusted City (FTP75) and Highway(HFET) fuel economy of 28.2715/39.8361 mpg. The EPA then downgraded them to the adjusted values of 22/28 which appears on the window label.
I am quite surpised to see the significant difference in unadjusted HW fuel economy between the 4WD sport mode (39.7 mpg) compared to the 2WD non-sport mode (30.8 mpg).