First, saying "If NHTSA's number are confirmed" and otherwise suggesting those are NHTSA numbers is misleading. Those are clearly labeled as "Tesla provided numbers" not independently collected statistics, say from insurance companies or DMV. Second, we really don't have the actual Tesla numbers to look at - how many cars, miles and accidents are we looking at here, statistics of few hundred accidents in a span of MY14-MY16 may not mean much. Third, again lacking apples to apples comparison, we don't know exactly what numbers Tesla considers serious accidents and how they compare with "serious" or "injury" accidents in the NHTSA study. Sorry, but given Tesla's history, I don't trust their interpretation of numbers - maybe what they meant to say is that AP is capable of 40% accident reduction, but currently limited by software, sensors or lack of compute power (this would an argument typical to Tesla, given their spin of numbers history with hp, battery capacities, etc.).
OK, you do not mention it but it seems we are now in agreement that the
2% reduction in serious injury accidents from AEB/FCW are not in the same range as the
40% reduction in airbag-deploying(serious) accidents reported in the NHTSA study after AP was enabled.
I think that's where our agreement ends (assuming it exists there).
You say that the 40% reduction in serious (airbag deploying) accidents is "clearly labeled as 'Tesla provided numbers'" and not NHTSA's numbers. That's not correct. The NHTSA report makes clear that the NHTSA's Office of Defects Investigation (ODI), not Tesla, performed the analysis, using "Data logs, image files, and records related to the crashes" subpoenaed from Tesla:
"5.0 CRASH INCIDENTS 5.1 Autopilot crashes. ODI analyzed data from crashes of Tesla Model S and Model X vehicles involving airbag deployments that occurred while operating in, or within 15 seconds of transitioning from, Autopilot mode.14 Some crashes involved impacts from other vehicles striking the Tesla from various directions with little to no warning to the Tesla driver. Other crashes involved scenarios known to be outside of the state-of-technology for current-generation Level 1 or 2 systems, such as cut-ins, cut-outs and crossing path collisions."
"14 Data logs, image files, and records related to the crashes were provided by Tesla in response to NHTSA subpoenas.
https://static.nhtsa.gov/odi/inv/2016/INCLA-PE16007-7876.PDF (page 8)
The ODI, not Tesla, analyzed data of airbag deployments and crash rates:
5.4 Crash rates. ODI analyzed mileage and airbag deployment data supplied by Tesla for all MY 2014 through 2016 Model S and 2016 Model X vehicles equipped with the Autopilot Technology Package, either installed in the vehicle when sold or through an OTA update, to calculate crash rates by miles travelled prior to and after Autopilot installation. Figure 11 shows the rates calculated by ODI for airbag deployment crashes in the subject Tesla vehicles before and after Autosteer installation. The data show that the Tesla vehicles crash rate dropped by almost 40 percent after Autosteer installation.
The ODI's analysis covered all Model Year 2014-2016 Model S and X with AP, a total of 43,781 vehicles according to page 1 of the report, and the ODI appears to have had access to a wealth of data. It used that data to investigate the exact concerns you have been raising, including "driver behavior factors" and "driver distraction" with AP (discussed on pages 9-10 of the report).
You say that you "don't trust Tesla's interpretation of numbers" but the report is the NHTSA's analysis of data logs, image files and other crash records provided by Tesla. It is the NHTSA's "interpretation," not Tesla's. The statement that "we don't know what Tesla considers serious accidents" is not relevant to the report -- the NHTSA did the analysis based on an objective criteria -- whether airbags deployed -- it did not rely on Tesla's assessment of what a serious accident would be.
So the bottom line is that the report makes very clear that the analysis, conclusions and numbers were all the NHTSA's based on data logs, image files and other records subpoenaed from Tesla.
As with any study there are limitations, as I said before. More data is always better -- maybe we'll get an update with more data along with the next NHTSA report. But a 40% reduction in serious (airbag deploying) accidents suggests the potential of this technology to save a very large number of lives, at a time when automotive fatality rates are rising in the U.S.
Ignoring the enormous life saving potential suggested by these results and claiming Autopilot is dangerous
with no data to support the claim IMO is unjustified.
When I was growing up and seat belts were not yet mandatory some people were afraid to use them because they worried they might get trapped in a burning car. Not an irrational concern (like the concern about driver distraction with AP), but the numbers suggest that any risk is far outweighed by the benefits. Although the data is still limited, the initial results on Autopilot are very promising and suggest that any risks from increased driver distraction are likely to be far outweighed by the benefits.