Actually that sounds about right for a VW Touareg (gasser) competitor, a GASSER Acura MDX.
Both a relative and I did a San Jose, CA to North and South Lake Tahoe, CA 10 day trip. He posted 20 mpg posted on the leg UPGRADE (sea level to 7,300 ft). We did plenty of stop and go to get to various ares include ski resort parking lots (6,250 ft on up)
On the second 5 days portion, we used the VW Touareg TDI. On the (same) UPGRADE and stop and go portion,s it posted 29.5 mpg or so.
I was not going to fill as the range is pretty close to 750+ miles. However for some reason. D2 was cheaper at the SLT, CA resort area than home AND in the flats, where I normally would have taken on D2 fuel. When the fuel station threw in a -$.10 per gal discount, temptation was too much

. I did fuel there on the down leg and the over all trip posted 31 mpg.
On the up grade leg portion, we had clear freeway for app 190 miles. I was able to keep it under 90 mph most of the trip, except for highway directional transitions. The last 23 miles were sloughing through snow and ice and 2 stop and go chain control points and farther up grade, fair idling time for what seemed to be a fatal flip over accident on two lane snow/ice covered roads. Coming out of the mountains, there was what seemed to be a 23 miles stop and go back up AND 2 chain control points.