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 States found in Utility Air Regulatory Group v. Environmental Protection Agency (573 U.S. 302, 328) that it is a core administrative law principle that an agency may not rewrite clear statutory terms to suit its own sense of how the statute should operate . (12) These invalid, ultra vires doctrines, and their uses, include— (A) an unlawfully broad interpretation of vessel equipment which conflicts with Congress’ statutory description of merchandise, and the explicit, limited statutory exemption