I think the horsepower gains are honestly about the same...to an extent. Lets say 2 typical bolt on 3.4 setup GTPs ( not a serious build) one has a plog/downpipe setup the other with headers. the plog downpipe one might put something like 230whp while the header one may put 230-232whp.Its not much difference hp wise however once you get into bigger more serious builds then the gains from headers would be larger more then likely. But otherwise flow is key.