Tesla CEO Elon Musk downplays fire risk.

Despite three recalls and a potential investigation by the National Highway Traffic Safety Administration, Tesla Motors founder and CEO Elon Musk insists “there definitely won’t be a recall” of the maker’s Model S battery-electric vehicle.

Speaking at a conference in New York also broadcast on CNBC, Musk decried as “extremely inaccurate and unreasonable” the reaction to reports of fires that have occurred in three Model S sedans since late September. Concerns about the vehicle’s safety, along with a series of negative reports by analysts following Tesla, have led to a sharp plunge in the maker’s once high-flying stock.

Musk was responding to growing concerns about a recall meant to address the possibility that the underbelly of the Model S might not be protected enough to prevent damage to the vehicle’s battery pack from road debris – blamed for both the first and third Tesla fires. On Monday, Jonathan Geller, tech editor for outlet BGR, had tweeted that a recall was under consideration.

An Instagram image of a third reported Tesla Model S fire in Smyrna, Tennessee. Photo Credit: TeslaMotorsClub.com.

While speaking at a New York Times conference today, CEO Musk declared, “there definitely won’t be a recall,” adding, “If fire risk is your concern, you’d have a great deal of difficulty being in any better car than the Model S (which) is five times less (a) fire risk than the average gasoline car. Moreover, we’ve never had a serious injury or death.”

In fact, Tesla over the weekend posted comments from the owner of the third Model S to catch fire, a Japanese doctor who noted that the vehicle’s warning system gave him ample time to pull over and exit the sedan before its front battery compartment erupted in flames.

“This experience does not in any way make me think that the Tesla Model S is an unsafe car,” wrote owner Juris Shibayama on the Tesla blog page.  “I would buy another one in a heartbeat.”

Despite such assurances, Tesla stock has been battered since the first fire was reported in late September, shortly after the shares traded on the NASDAQ under the symbol TSLA hit a $194.50 peak. Tesla’s stock closed on Tuesday afternoon $137.80, another $6.90, or 4.8%, decline for the day.

There have been other factors hurting Tesla, however, including a third-quarter earnings report that disappointed many analysts – especially when Musk warned during a conference call that the maker was short of the batteries it needs to meet its current order bank.

Tesla has, if anything, been exceeding its own expectations and anticipates delivering 21,500 of the Model S sedans – which sell for between $70,000 and more than $100,000. But it has apparently shifted some vehicles from the U.S. to Europe where it is currently setting up a distribution network.

But observers worry that Tesla could see demand slip if potential buyers start to worry about safety issues. Indeed, there have been numerous problems with lithium-ion batteries in recent years, including a fire on a cargo jet that crashed in the Mideast.

Tesla did have a small recall involving about 1,200 vehicles, but the June service action was the result of problems with a rear seat mounting bracket.

While Musk may be ruling out a recall, he could still be overruled by NHTSA which last week announced a preliminary investigation into the Model S fires. There is no way to determine if that probe will progress, but should the agency determine there is a potential defect it could move to force Tesla to take actions that might include a recall.