I did read the linked correspondence and would point out that Tesla does not reference any particular type of crash or vehicle weight and simply makes the assumption that - on average - a lower scoring car is safer. If this is true then Tesla’s claims all make sense and follow quite organically from the test scores. If a lower score does not have any correspondence to safety and likelihood of injury, then I think we have a bigger problem of the testing being unrelated to safety!
This happened quite a while ago and the blog post by Tesla is still live. To me this means that while the agency doesn’t like automakers referring to anything beyond the “star rating”, they don’t think Tesla has actually said anything incorrect or misinterpreted the data.
