In the sticker, take a look the the range printed at the bottom of two big number printed . It will tell you some of the variations of the engine. I do not by have the 35i. So, I can't look it up. I am not surprised you can go lower than city rating by epa.

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2012 BMW X5 Vermilion Red Xdrive35d with Premium Package, 3rd Row Seats, and Adaptive Drive