... The diameter of the nozzle is constrained by fitting nine of them on the bottom of the Falcon 9, which is itself diameter constrained. To take advantage of lower base pressure, the nozzle would have to get larger and it can't. ...
Remember that RS-25 is a sustainer, burning from launch to disposal orbit. Extreme efficiency is required to squeeze out every second of ISP. And this costs money. One of Merlin's efficiencies lies in cost. (Another is T/W.)