According to UMTRI, it uses EPA mpg (window sticker mpg) not CAFE mpg.

Yeah. But the author failed to note that:
- Ford was dead last with the lowest combined MPG (cars and trucks) in 2011 at 17.3 MPG;
- in 2012, even after Ford’s ‘signiifcant’ improvement, it still ranks 1 MPG BELOW the industry average. Ouch!

Although bureaucrats may make the regulations (and usually give themselves credit for the results), the engineers and the corporations must do the far more difficult work of making the products and then selling them. Unless those products are appealing and cost-effective, potential buyers may just decide to keep their older vehicles.

CAFE figures have little to do with actual vehicle mileage — they are substantially adjusted with “voodoo math” calculations for reduced mileage with ethanol, estimates of equivalent mileage for electric vehicles, etc.