What size are your winter tires? My wife has Barum Brillantis2 175 65 r14 tires, very cheap and loud but robust in tread depth. Since putting those on with Vision Cross 14x5.5" alloys, her mpg has dropped to about 35mpg combined.
My 2021 has OEM alloys 14x4.5" and new OEM Falken 165 65 r14 tires and I avg about 39 combined.