I really liked what you were saying until you you got to:
Of course it's an agency problem. Agencies should write their minimums so that meeting them produces the quality they want from their divers. An instructor is allowed to accept the absolute minimums in the standards. Instructors are allowed to do so by the agencies. If those absolute minimums aren't high enough, the agencies need to raise them. Until agencies do raise their standards, I agree we should encourage instructors to exceed those minimums. Don't blame instructors for doing what the agencies have said is OK.
Let's see how this works in other areas of education.
Over the last few decades, a number of educational researchers have tried to do studies in which they compared the effectiveness of one educational program to another. In theory, one should be able to look at the educational results of a school that has adoped one program and compare it with the educational results of another program. The problem is that most researchers have found this to be an impossibility because no matter what program the schools adopted, once an individual teacher closed the door of the classroom, that teacher tended to revert to whatever he or she had always done, which was usually the way he or she had been taught originally.
This was the major flaw in one of the most famous educational studies of all time, the Coleman report of 1968. This report compared the results of schools and determined that instructional methods really didn't matter, for educational results were determined by the skills and the socio-economic status of the students attending the school. That mistaken conclusion is still haunting us today.
Coleman's report compared whole school results. Later studies, notably the Starr studies in Tennessee, examined the effects of individual teachers on student achievement and found significant differences, even within the same school. Some teachers demonstrated excellent achievement results year after year, and others had consistently poor acheivement results year after year. One study I recently read indicated that if a child were identified as at-risk for reading in 2nd grade but had two consecutive years of demonstrated good instruction in 3rd and 4th grade, that child would almost be guaranteed to become a proficient reader. In contrast, a child who was not at risk in 2nd grade would be at risk for being a non-reader by 5th grade following two consecutive years of poor teaching. Research over the last few decades has totally reversed Coleman:
it is the individual classroom teacher and the instructional decisions that teacher makes that have the greatest impact on education.
I myself conducted research studies of this kind. In one school's performance on a 10th grade writing assessment, the school reported 57% of students proficient. There were eight 10th grade teachers. Two had 100% proficient, two had more than 80% proficient, and the remaining four were below 20%. These are eight teachers in the same school, with years of training, the same credentials, the same program, and the same administrator oversight.
In my current work, I oversee the instructional theory behind the design and development of course curricula. We interview curriculum writers carefully to get the best prepared candidates possible, we train them to our system, and we oversee the results. Believe me, dealing with their screwups is the biggest headache in my daily life. They all tend to go their own way rather than the direction we have set for them.
Although I never finished my dissertation, I did complete all the course work for my Ph.D. The quality of the courses I took in graduate school was ridiculously uneven. In one memorable course, the syllabus had less than a 10% overlap with the title of the course. In another course, the obviously alcoholic professor missed 25% of the classes and was late for pretty much all the rest. We complained, and the professor was obviously spoken to, but that really did not do much for our education.
So, if the world of professional education, with all of its resources, professional training, and close oversight, cannot manage the quality of its instructors, why would any agency be able to do better?