Sunfish, the problem is that no matter how good or bad the starting and enpoints are the transition has always been set out in stages. You end up having a mixture of the new and the old leading to confusion. Learning to operate in a new system primarily by using it where lives are at risk is a serious issue that education alone clearly can't handle properly. It's a bit late for a pilot to discover gaps in their knowledge or subtleties that they failed to grasp when they're failing to separate themself from a 737 near Launy.
The system might work well in the US because it's a mature system that they all grew up with and were trained to fly in from scratch. How is it possible to transplant that directly to another country? You can bring all the rules you want but that doesn't bring the generations of cultural knowledge that goes with it. The little tricks you pass on to new pilots on how to make it all work that aren't part of the rules.
Dick has admitted further up the thread that this goes on with controllers - they don't actually do what it says on the NAS tin, so even if we followed the NAS model we wouldn't be providing the same service.