These points are important factors, but consider that human-supervised FSD Beta is approaching commercial aviation levels of safety. We are talking about a 1000x difference from average.
The program has 100k drivers, which as
@Singuy estimated is around 7% of Tesla’s entire American customer base. I would guess that around a third of them are in the LA and SF areas, where collision rates are much higher than the US average. In these locations maintaining a big following distance is almost impossible because of aggressive, opportunistic drivers who will take that as an invitation to cut in.
Is 7% of Tesla’s owner pool elite drivers who can match the safety of commercial aviation all by themselves simply by picking the right routes and exercising the normal level of caution they previously had before becoming a Beta tester? I highly doubt it.