Statistically it wound seem that it is, but it we are not comparing like with like here. Looking at the set-up, it's hard to see how anyone other than USA, Mexico and A.N. Other will be the qualifiers. You could argue that it would be as difficult for El Salvador, say, to qualify as it would be for someone like Ireland when you look at the opposition and seedings. But not USA v Ireland. USA will have a much better chance of qualifying. In the European groups there 5 or 6 certs. For example, in the upcoming qualifiers Germany are the no.1 seeds in Ireland's group and are nailed on to qualify. They've never failed before. So before a ball is kicked Ireland are in a 4 team battle for 2nd spot (I'm excluding the Faroes obviously), which only guarantees a play-off spot against another 2nd place team.
Interesting debate though.
I'm glad you pointed it out, I didn't explain it well. Yes, 1-in-4 make it in UEFA vs 1-in-10 in CONCACAF, but there is a much higher average quality level in Europe, that is without a doubt. Most of the low CONCACAF teams sink to the bottom and are eliminated in the first round, most the stronger sides never see them as they are given first-round byes. Yes, there are the Moldova's, Lichtenstein's, Faroe Islands, San Marino's, Azerbaijan's, Armenia's, etc... in UEFA, but there are a huge number of Caribbean Islands too that frankly are probably no better than a mediocre 3rd division club team to be honest.
It's the games played in the bigger Central American countries that get pretty crazy, those are not easy places to play at - exceedingly hostile environments. I could see the fringe teams in UEFA, the Ireland's, the Ukraine's, the Russia's having trouble winning those games for sure, just like the bigger CONCACAF teams have trouble. Countries like Honduras, El Salvador, Costa Rica, Guatemala are pretty good teams to begin with, usually have a lot of speed, and are bolstered by the miserable conditions they make opposing teams face. So it's no cakewalk getting through CONCACAF and with only 3-guaranteed slots the fourth qualifying round becomes very heated and competitive.