London — England and America speak the same language, it sometimes seems, the better to misunderstand each other.
Nothing looks more similar, on the surface, than the role of the House of Representatives and the House of Commons. Nothing could be more deceptive. Let us make a comparison on the spot: first the American version.
You raise your arm; the taxi stops. ''House side of the Capitol,'' you say. The cab takes you up Pennsylvania Avenue, past the White House. Here they demobilized the last Union army after the Civil War, pelted the cannon with flowers; it is a historic spot. Over there in the Willard Hotel Julia Ward Howe wrote ''The Battle Hymn of the Republic.'' In the same hotel, thrifty Calvin Coolidge saved money by renting rooms when he was vice-president.
Inside the House of Representatives, you look down from the press gallery. They debated the budget till 1:15 this morning and have resumed it again at 10 o'clock. The place looks like a bus depot. A voice is saying indistinguishable things over the loudspeaker. There are crashing cracks from the Speaker's gavel. ''Order, order!'' It is a big semicircular auditorium with galleries, a slight slope to the floor and the podium occupied today not by picturesque white-haired Speaker Tip O'Neill, but by a substitute.
Result: The federal budget that President Reagan sent to Congress in February has still not passed in mid-June. This is the fifth day of debate, and on this go-around, seven budget plans and scores of amendments have been offered. When the Democratic House finally does act, it will find that the Republican Senate has already passed a different budget, and these must be reconciled.
''Nothing in our federal government is more in need of an overhaul than a ridiculous procedure we have misnamed the budget process!'' Ronald Reagan exclaimed from California.
Mr. Reagan made his comment to newsmen who, in a kind of ex-officio job, participate in the American government by asking questions of the separate divisions of House and Senate and particularly bridge the chasm between executive and legislature.
Very well, then, that is Washington. Now let us make a big shift. Here we are in London - in Westminster, which has been called the ''Mother of Parliaments.'' It is a special day, because President Reagan, back from the Versailles summit meeting, has this morning addressed both Houses of Parliament in the Royal Gallery. He has given a low-key speech, received warmly. Now it is the afternoon of the same day. This is the venerable chamber of the House of Commons itself. It is about to see enacted what some call the best matinee performance in London , the thing that dramatizes better than anything else the differing style and procedure of the parliamentary and congressional systems: ''Question Time.''
There is Margaret Thatcher, the prime minister! She is seated in the first seat, in the front row, beside the Dispatch Box (and, in this hoary and venerable place that reeks of tradition, close to the great Gold Mace that symbolizes authority). On the right, as we look down from the press gallery, is the Conservative coalition. On the other side, the opposition with the members of the Labour Party ''shadow'' cabinet, led by Michael Foot, sit in their ceremonial front row.
Margaret Thatcher, we note, is not answering her critics from 3,000 miles away; she is right here in this big but somehow intimate hall, face to face with and answering questions of her opposition. The procedure follows an intricate protocol, understood in most other parliamentary governments. The visiting American remembers that his form of government (which seems so normal back in humid Washington) is the oddity to most of the world. Of a hundred or more new governments formed since World War II none, I believe, follows the American pattern. The story was told this morning by the Lord Chancellor Hailsham in introducing President Reagan. With reference to the American Revolution, he said:
"When our paths diverged 200 years ago, the United States reverted to the earlier 17th-century model of an executive head of government, independent of the legislature as well as of the judiciary. We, and other nations sprung from the loins of the earlier parliaments, pursued the system already recognizable at the time of the Declaration of Independence, of an executive drawn from the legislature but independent of the head of state.''
American historians might shade it a bit differently, but there the two systems diverged. How would it be today to have Ronald Reagan and his Cabinet right down there in the well of Congress, answering questions - not of newsmen, but of opponents from across the aisle? It is hard to imagine, but it makes a good show, anyway!
If Tip O'Neill were the Speaker of the House of Commons, he would sit in state and wear a wig. At the far end of the big hall rise nine tiers of spectators' seats. On the floor below, separated from each other by a little cleared quadrangle, the rival political teams sit facing each other almost eyeball to eyeball. Each questioner is allowed one follow-up oral query, and if it comes from the opposition it is designed to trip up the government. It is noisy and boisterous, perhaps too much so. After four years of broadcasting, some MPs worry about the impression they make. Too rowdy. In a report just issued by the Select Committee on Sound Broadcasting, more than 300 MPs answered: 76 percent are satisfied, but Raymond Fletcher (Labour: Ilkeston) charges that ''question time is rarely anything but knockabout stuff performed by amateurs.''
Maybe so. But marvelously stimulating. Sometimes I had a feeling that an almost maternal note was coming into Mrs. Thatcher's voice as she continued formal answers through shouts of dissent. There was no outright clapping, even when the victorious Tory candidate from the by-election of Merton, Mitcham, and Morden took her seat. There was a prolonged manifestation of approval, a chorus of ''hear, hear,'' which sounded like a drawn-out ''Yeah!'' tailored not to violate some ancient taboo or other.
America, where presidential election turnouts have dropped since 1960 to an alarming 51 percent, and where political parties in many areas have all but decayed, desperately needs, I think, some stimulus: Perhaps a modified Question Time might help. Unlike President Reagan, Mrs. Thatcher does not need to worry about her budget; if it weren't adopted in a few weeks there would be a new election.
Ronald Reagan is both head of state and head of government - Queen Elizabeth and prime minster rolled into one. He is more than Mrs. Thatcher because his Cabinet members are presidential assistants, dismissible at will; and yet he could not get his budget passed. He carries the mystique of the White House, however.
Philosopher Walter Bagehot analyzed the inner need: People instinctively want someone to symbolize the nation as a whole. Men are not simply rational beings, and the irrational in them demands recognition. One way is to simplify and personalize complicated matters.
The most vexing governmental problem in America today is where the responsibility lies. Lloyd Cutler, an adviser to former President Carter, writing in Foreign Affairs, said, ''We cannot fairly hold the President accountable for the success or failure of his overall program, because he lacks the institutional power to put that program into effect.'' More and more writers anxiously deal with this point.
''Almost every writer about the contemporary presidency,'' writes Prof. Richard Rose, ''emphasizes the widening gap between what a President is required or expected to do and the resources at hand.''
Under Vietnam it looked as though Congress were going to take over the power of making war as well as the power of the purse, but the move faded. Now the drift may be the other way. One thinks of these things, watching the British solution in the awe-inspiring setting of Westminster with Maggie Thatcher frostily answering in Question Time.
The United States has the oldest continuous constitution of any modern democracy. ''What is needed in America,'' concludes Professor Rose in ''Presidents and Prime Ministers,'' ''is not simply a stronger President. What America needs most of all is a stronger government.''