I used to think this, but then I got a Model 3. I believe that FSD is presently better than most humans driving today even when they are theoretically “fully engaged in manual driving”.

FSD doesn’t lull humans into a false sense of security, humans do. FSD doesn’t let you use your phone while it’s on. This alone is an upgrade over most human beings, who think occasional quick phone usage while driving is fine (at least for themselves).

I believe that if you replaced all human drivers in the US with FSD as it exists today, fatalities would go down immediately.

Humans are not a gold standard, and the current median human driver is easy to outperform on safety.