Yes. Basically someone made a formula years and years ago about what they believed new cars mpg would be based on very generous speculations. And it’s never been adjusted. The formula is based on the a bunch of variables but ends up boiling down to altering the footprint.
The reason is years and years ago the EPA formula set some goals based on speculation that future technology would keep up pace. And we can’t achieve those goals. But car manufacturers can increase the footprint of their vehicles to move the goal post.