I'm not reading a position in what you've said, but there is an observation here to draw out for the crowd. It doesn't matter all that much if after controlling for those variables it is relatively less safe; in absolute terms it just needs to be as safe as the worst human drivers.
That is, we have an accepted safety standard - by definition, the worst human driver with a license. If a Tesla is safer than that, the rest is theoretically preferences and economics.
I'm not saying that the regulators or consumers will accept that logic - if airlines are any example to go buy, they'll take the opportunity to push standards higher - but I think the point is interesting and important. It is easy to smother progress if we don't acknowledge that the world is a dangerous place and everything has elements of risk.
I don't agree with this position. Autopilot is a new thing that governments need to decide whether it's allowed or not (since it is operating dangerous equipment, so the state has an interest in doing the right thing). If improved safety is not a demonstrably valid argument for allowing it, it IMO doesn't pass the bar for what should be allowed. At that point it's purely a money-grabber from corporations that want the cookie (first to market with fully autonomous vehicles) without paying for it (heavy investment in testing).
Since it would be one software being used many times over, I'd be fine if it could pass a large number of driving test with very low failure rate, considering driving tests are quite random in how they are applied. The question is however which driving test. My experience in Switzerland was that the practical driving test was quite hard to pass, I had to train a lot to satisfy them completely and they route you for one hour quite randomly around a European medieval town and its outskirts, i.e. a place that's quite hard to navigate correctly as it's not built for cars.
That is, we have an accepted safety standard - by definition, the worst human driver with a license. If a Tesla is safer than that, the rest is theoretically preferences and economics.
I'm not saying that the regulators or consumers will accept that logic - if airlines are any example to go buy, they'll take the opportunity to push standards higher - but I think the point is interesting and important. It is easy to smother progress if we don't acknowledge that the world is a dangerous place and everything has elements of risk.