Does 6 certified approaches in 6 months make you any more or less safe than demonstrating your competence and making your next approach nine months later? Both of course meet the requirements.
Fuji Abound
I think what he is getting at is that under the self certified system, a pilot can fly an instrument approach and a hold every month in VMC, make a total hash of it but delude themselves into logging it as a great approach suitable to be counted towards the requirements. They then continue to delude themselves for 10 years until they have to do it fro real and they either cause a total mayhem in the system and survive or win themselves the aviation version of the Darwin award.
Under the yearly renewal for the ICAO IR or 2 yearly for the UK IMC, there is an independent check of competence.
Remember that if you fly in the US, the FAA oversight system is very much in evidence. You can not put much of a foot wrong at an airfield without at best being given a good pointer from a local CFI/CFII at worst, the local FAA guy having a severe word in your ear.
That oversight is not provided in Europe.
The more European PPLs fly N reg aircraft and use FAA ratings to fly within Europe, the more the pressure will be politically and from the NAAs to sort things out.
So those that seek the demise of the European pilot flying N reg IFR on a US LICENCE are best served by encouraging more and more pilots to follow that route.
They are also best served by having few pilots using that system.
In terms of numbers it is a loose loose position for N reg operators / FAA licence holders based in Europe - too many holders puts more pressure on governments to crack down.......too few and they have too small a voice to prevent any change.
Regards,
DFC