I think if you make a decent, non buggy game, in a decent genre, and do some of the minimum work required to promote your game (steam next fest, promote to streamers, enter festivals) you will not be in the sub 10 range.
But I also know that the lowest tier of games that earn fewer than 10 reviews is bigger and not earning much. I made this chart for my last blog and you can see the dramatic increase of the blue zone. I think if you make a decent, non buggy game, in a decent genre, and do some of the minimum work required to promote your game (steam next fest, promote to streamers, enter festivals) you will not be in the sub 10 range. But how much further can you rise?