I think that's mostly true.
However, this is a Federal Agency taking official action. It has the feeling of FUD that is better organized and funded at higher levels and might have longer staying power. It requires a sustained lobbying at the agency (in this case I think the NTSB), maybe even getting people sympathetic to your cause installed at high levels within either that agency or, heaven forbid, the administration at the executive level. I think it's part of a longer-term FUD campaign that is not driven by Wall Street shorts or other financial types but by big auto and maybe even funded by big oil via big auto. This is not a wacky conspiracy theory, it's how the world is proven to work. Yes, it's a sad reality and no, it's not funny.
That's what this has the feeling of. Up until now the NHTSA seems to have mostly resisted pressure to use a heavy hand with Tesla. They are a pragmatic, data-driven agency as far as federal agencies go. But the NTSB is a different type of agency, more political and more corrupt. None of this means this effort will be effective - the bad actors could end up being laughed out of town (lose influence). Or, it could be a building movement. It matters how robust and well planned the effort is. The late timing of this effort potentially indicates something that has been in the works for a couple of years or more.
More research into the recent histories of changes of the people with influence within these agencies is called for in order to be able to draw better conclusions.