To be precise, the FAA makes no such assumptions, instead they directly quote the results of an independant Aerospace Corporation Technical Report (included as an annexure to the FAA submission)
https://en.wikipedia.org/wiki/The_Aerospace_Corporation
https://www.faa.gov/sites/faa.gov/files/Report_to_Congress_R...
These are based on 1970s VAST studies on reentry debris survivability which are applied to the the SpaceX satellite tonnages and upper stages of launch vehicles.
The FAA explicitly qualifies this with:
If SpaceX is correct in reporting zero surviving debris, as SpaceX reports in FCC filings, and Starlink is a fully-demisable spacecraft, the rise in reentry risk is minimal over the current risk.
The question the FAA poses is "IF ...
as SpaceX reports ..." and they suggest that is a area worth careful scrutiny.