Do you have any proof of this? I can enable it on a dirt road if there are visible enough edges of the road.
But yes, obviously, they're being a bit misleading by aggregating all miles together. In aggregate, it is overall safer on the highway, and I don't think you can argue in good faith that the safety report is wrong about that.
https://www.tesla.com/ownersmanual/model3/en_us/GUID-101D1BF...
> In addition, these features may not work as intended when: The road has sharp curves or significant changes in elevation.; Road signs and signals are unclear, ambiguous, or poorly maintained.; Visibility is poor (due to heavy rain, snow, hail, etc. or poorly lit roadways at night); You are driving in a tunnel or next to a highway divider that interferes with the view of the camera(s); Bright light (such as from oncoming headlights or direct sunlight) interferes with the view of the camera(s).
https://www.tesla.com/ownersmanual/model3/en_us/GUID-E5FF5E8...
> Full Self-Driving (Beta) and its associated functions may not operate as intended and there are numerous situations in which driver intervention may be needed. Examples include (but are not limited to): Interactions with pedestrians, bicyclists, and other road users.; Unprotected turns with high-speed cross traffic.; Multi-lane turns.; Simultaneous lane changes.; Narrow roads with oncoming cars or double-parked vehicles.; Rare objects such as trailers, ramps, cargo, open doors, etc. protruding from vehicles.; Merges onto high-traffic, high-speed roads.; Debris in the road.; Construction zones.; High curvature roads, particularly at fast driving speeds.
For example, there's quite a bit of evidence that lane departure warnings/assistance helps: https://www.consumerreports.org/car-safety/lane-departure-wa...
Less indication backup cameras do anything: https://www.latimes.com/business/la-fi-hy-back-up-cameras-20...
Tesla's non-autopilot numbers likely reflect the fact that they're exclusively newer vehicles with safety features that aren't yet widely standard. You'd probably see similarly nice numbers for other $50k+ luxury vehicles with similar bells-and-whistles.
This is probably not possible since those automakers don't do constant data collection in the same way Tesla does. Tesla's telemetry logs actual data for the distance their cars are driving and whether AP is enabled. All we have for other brands is NHTSA's approximations.
Autopilot will refuse to engage in a wide variety of situations. It will only engage in the easiest, safest scenarios. You cannot compare those miles against all miles driven by human drivers, which include narrow winding mountain passes, two inches of snowy slush, etc.
Even the 1M non-autopilot comparison; you're comparing against a car population that includes 20 year old beaters with far fewer safety features.