You make a solid point about ethanol in the fuel. Most northern states add 10%.
Using that information, here's the revised formula...
Advertised MPG = 23 MPG Combined
10% Ethanol fuel = -2 MPG = 21 MPG Combined
FE Style roof rack = -4 MPG = 17 MPG Combined
BFG All Terrain Tires = -2 MPG = 15 MPG Combined
Go with pure gasoline (If your state sells it) and you'll be closer to the advertised fuel economy.
@EOD Guy Does your state sell Ethanol free gasoline? That could account for you averaging 18-20 MPG.