I'm not sure you can use
Better to describe either system, just
different. Clearly the eventual product, the experienced ATP, is basically the same from both sides of the pond. The problem is that there are a number of points on the way that do not correspond to each other.
We can see this in other spheres. A UK PhD is approximately the same as a US PhD, but the BSc is different. The result being that a UK PhD program will typically have little or no coursework compared to the US one. The end products are the same, but a US BSc entering into a UK PhD program is likely to be out of his/her ilk for a time.
Similarly with piloting, the JAA CPL/frozen ATPL has no real equivalent in the FAA world: A fresh FAA CPL is not ready to sit right seat in an airliner, because the system is not set up for that (although whether a fresh JAA FATPL is either is an open question
). Thus expecting an easy transfer to JAA CPL is not realistic.
On the other hand some maneuvers to only allow JAA training in member states is clearly just protectionist. The arguments about weather and terrain don't make much sense considering the wide variation of weather and terrain in the EU.
[ 09 July 2001: Message edited by: What was the DH again????? ]