It does look extremely pessimistic. Like one of the 'incident' is that they hit a curb at a parking lot at 6 MPH.
No human driver would report this kind of incident. A human driver would probably forget it after the next traffic light.
While it's clearly Tesla's fault (if you hit any static object it's your fault), when you take this kind of 'incident' into account of course it'd look worse than humans.
The human data estimate they compare to to get the 3x number also includes this type of incident - even if of course no one reports it, you can get some idea of the number of such incidents based on service and paint shop data.