The biggest kicker in starting an agency in the United States is liability insurance. If you can find a reputable insurance company that will issue you a liability policy to your instructors to teach scuba under the policies and procedures you set down, you can be a legitimate agency. (In fact, you could start an agency without insurance, but that'd be terminally stupid) As the RSTC and ANSI standards for Scuba instruction are public domain, using those as your basis should make getting the insurance fairly straightforward.
Whether or not you can make it go is another matter... Being "self regulating" leaves air-fill stations and dive operators free to honor any "C" card they want to - (indeed, the only thing that makes a "C" card a requirement at all is the fine print in the dive operator's own liability insurance policy) - or to not honor it. As recently as two years ago, for example, Red Sail Sports in Cayman refused to honor an IANTD Nitrox card as a "C" card for basic scuba diving! Unbelievable but true. Those kinds of incidents can kill an agency in its infancy. On the other hand, in the Western Pacific operators are accustomed to seeing all kinds of cards from thy myriad tiny agencies in Japan and elsewhere, and are more prone to accept just about anything.
A couple of "recent" startups in the States are NASE (1982) and MDEA (circa 1985). (both over 15 years in business) - have you ever heard of either? You hear a lot about another newbie, GUE, on this board, but in most of the recreational diving world "GUE" will only get you a "Who?" In other words, starting an agency is pretty easy - but it is not a "get rich quick" scheme.
Rick
