I would be surprised if the rack or injectors aren't out of spec. It can run well, but without everything balanced it isn't efficient. I'd also look at dragging brakes, possibly a fan clutch that is not releasing, something. I drove my 190Dt hard, but always turned mid-upper 30s in mixed driving, ... low 40s on a long mostly 2-lane run I made occasionally. I made my calculations with the GPS, maybe you've got a happy odometer?
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