I doubt it. Yes, FSD is more flexible and can also drive reasonably well on city streets, but there is a reason why it is not certified for level 3 on motorways. It would most likely fail certification. With a level 3 system, I can take my eyes off the road and watch a movie. Doing that with FSD, even in the best conditions, is suicidal. Level 3 vehicles must have an extremely low failure rate. Any crash would quickly be picked up by the media.
FSD is a versatile level 2 system, but at best a prototype for level 3. If we are talking about prototypes, it has to be compared to prototypes from other manufacturers like this <https://www.youtube.com/watch?v=0uSph0asNsk> fully autonomous system from ... 11 years ago. The reason FSD is available to the average consumer is mostly a matter of philosophy, not technology.