OK, thanks, I better understand the focus of your comment. And, I agree. PADI does allow for Instructor 'Indirect Supervision' on the tours, meaning a DM can lead student divers (at a 2:1 ratio) on those activities. Personally, I don't feel comfortable with 'Indirect Supervision' in that situation, and while I often have DMs lead a tour, I am always part of the tour. In addition, in the shop where I previously trained and taught, we required DMs to become SRD-certified since they are regularly put in the position of diving independently. I do not consider diving with an uncertified student to represent 'buddy diving, either, so leading a tour without another certified diver present is independent / solo diving. I would prefer the minimum # of dives for DM certification be be reset to 100.