It's not un-acheivable....this was my avg. in my 3.5 after a ~100 mile round trip driving about 65mph. I didn't hand calculate this specific trip, but normally when I do it's within 1-1.5mpg. My mods are aem intake, y-pipe, and nismo exhaust. That was driving like a grandma, but it's possible. I think "opening" up the intake/exhaust flow with bolt-ons can improve mpg's, but the hard part is driving slow once you have the mods lol.
kinda OT, but this was my avg. doing the exact same ~100 mile round trip @ 65mph in my 2004 e60 545i
Keep in mind that it has a 4.4L V8 with 325hp and 330tq. :-0