Earlier quoted context omitted.
Why? It involves a safety system! That needs to be tracked publicly and updated! Nothing more than an OTA - does not mean much when everything is fly by wire and a bug could mean your car does not stop accelerating or something.
Recall implies something being returned. This should be called a mandatory software patch, or something like that. The problem is Tesla owners repeatedly see "recall" to mean "software update", so this might lead to a lot of confusion if a physical recall is actually required in the future.
I had a VW car that was "recalled" shortly following the emissions scandal. The dealership asked me to come in for a free software update related to emissions. So you can say it's a "recall" to the lawmakers but call it a "free software update" to the user.