It is kind of comparing apples to oranges. The more appropriate would be to compare it with other Taxis.
https://www.rubensteinandrynecki.com/brooklyn/taxi-accident-...
Generally about 1 accident per 217k miles. Which still means that Tesla is having accidents at a 4x rate. However, there may be underreporting and that could be the source of the difference. Also, the safety drivers may have prevented a lot of accidents too.
I'm sure insurers will love your arguments and simply insure Tesla at the exact same rate they insure everyone else.
I think Tesla's egg is cooked. They need a full suite of sensors ASAP. Get rid of Elon and you'll see an announcement in weeks.