Rather than drudging up this tired topic yet again, I'll suggest again: come up with a better answer. I'm not just trying to be difficult. Seriously.
How about this:
- Test in 10mph increments between 20-80mph.
- Test in 10º increments "temperature-soaked" between -20ºF and 120ºF.
- Skew the results based on Cd and an average, say, 5kt headwind.
- Combine these tests to show every permutation on a graph. In a controlled lab this shouldn't be insanely hard?
- Most people probably won't take the time to read and understand those plots, so use, say, the 70º 70mph test for a "highway efficiency."
- Add in stop-and-go acceleration/deceleration every quarter mile or something (average how often cars stop in a city for traffic or intersections), combine with the 70º 30 or 40mph results for a "city efficiency."
- Now do the same for ICE vehicles. Show in both the native unit for each (mpg, mi/kWh) and a common unit that can actually be compared (e.g. kW). For the whole graph.
I'm sure I'm missing things, but that sounds a hell of a lot better as a starting point to me than what we're currently arguing about. And really, as
@Bobby said, if we come up with an answer that we like, write your congress people and quit arguing about it on the internet.