Isn't it a catch 22? How do you provide the data that it is safe without testing it to collect the data?

It would be but Tesla charged ahead and put its vehicles on the road.

Well yes, that is my point. How else would they ever acquire that data if they didn't charge ahead? You are asking them to accomplish an impossible task to release the data without having a way to acquire it.

I don't think this is a good faith answer; feels more like "I don't have a good answer for why this is a problem, so I'm going to punt it onto you to convince me"

Disagree. It is a good faith answer which states standard practice for safety standards.

Burden of proof is on Tesla to show that FSD is safe, not on the DMV to prove that it isn't.

You are welcome to argue that this principle is in need of reform. People may or may not agree with you. The discussion might be interesting.

But like it or not, the underlying principle for an exception to an established safety principle is that the burden of proof is on Tesla.

The only ones who have the hard data are Tesla and you are expecting somebody else to provide it. Are you serious?