I agree with most of your points and your conclusion, but to be fair OP was asserting that human drivers under-report incidents, which I believe. Super minor bumps where the drivers get out, determine there’s barely a scratch, and go on. Or solo low speed collisions with walls in garage or trees.
I don’t think it invalidates the conclusion, but it seems like one fair point in an otherwise off-target defense.
Sure, but the 3x comparison is not based on reported incidents, it's based on estimates of incidents that occur. I think it's fair to assume such estimates are based on data about repairs and other such market stats, that don't necessarily depend on reporting. We also have no reason a priori to believe the Tesla reports include every single incident either, especially given their history from FSD incident disclosures.
I don’t think it invalidates the conclusion, but it seems like one fair point in an otherwise off-target defense.