it institutes a public notice and comment process to modify or revoke that interpretative guidance. As a result, CBP and market participants treat as binding ruling letters and interpretative guidance in addressing whether and how the Jones Act applies in substantially identical factual situations. (7) Thus, CBP’s ruling letters—even if legally incorrect—have substantial impacts: When CBP purports to authorize a foreign vessel to transport merchandise between coastwise points, unless ordered by a Federal court to rescind such ruling letters, CBP does not take enforcement action against other foreign vessels engaging in substantially identical transactions, and vessel operators accordingly rely on CBP’s past ruling letters and guidance issued to other parties. (8) Over several decades, CBP has purported to create an array of exemptions from the prohibitions of the Jones Act for the benefit of foreign vessels. (9) On December 11, 2019, CBP published Customs Bulletin and Decisions, Vol. 53, No. 45 (hereinafter referred to as the 2019 Decision ) revoking a handful of its interpretations, recognizing that the analyses employed therein were inconsistent with the Jones Act and original congressional intent, including by using statutory language out of context, having been superseded by amendments, or being predicated on CBP-created distinctions that had always been irrelevant under the Jones Act. (10) However, the 2019 Decision still left in force many ruling letters inconsistent with the Jones Act and original congressional intent, espousing the same unlawful doctrines, revoked others that properly interpreted the Jones Act, and created several new loopholes that purport to immunize much of the same foreign vessel activities that are now, and have always been, prohibited under the Jones Act. (11) Thus, CBP has created invalid exemptions from the prohibition embodied in the Jones Act, using a variety of new and old doctrines inconsistent with original congressional intent. In 2014, the Supreme Court of the United