A little more research reveals that the MARAD waiver program only deals
with coastwise endorsements to the documentation process, not the Great
Lakes endorsement, so it does not apply to my Canadian-built boat.

The Passenger Services Act states in full "No foreign vessel shall
transport passengers between ports or places in the United States,
either directly or by way of a foreign port, under a penalty of $200 for
each passenger so transported and landed." This means that as long as
these are cruises or boat rides and I return my clients to where we
embarked, I am in compliance. The Jones Act only applies to cargo.

In reading over 46 CFR 67.7, it states, "Any vessel of at least five
tons which engages in the fisheries on the navigable waters of the US,
or in the EEZ, Great Lakes trade or coastwise trade" must be documented
and properly endorsed. It's not clear to me in this section whether this
means I can't let my clents fish in the Great Lakes without
documentation or that I can't "engage in Great Lakes trade" without
documentation.

The use of this term "Great Lakes trade" isn't clear to me. Is it just
to define the fishing area of the Great Lakes or does it mean some
activity that's not defined anywhere in the CFR that I could find?
Section 67.19 (b) talks about requiring a Great lakes endorsement for
"employment in the Great Lakes trade" but doesn't define it.

Another interesting angle is that 67.19 (c) (3) states "Vessels granted
coastwise trading priviledges by special legislation (67.132) can get a
Great Lakes endorsement. The MARAD waiver program might be defined as
"special legislation," but I can't find CFR 67.132 anywhere.

In reading over all these regs, I'm thinking that to take people out on
cruises on the Great Lakes on a non-US-built boat, I might not need to
be documented at all, as long as I don't transport them from one place
to another or let them fish. I'm trying to get written documentation of
the USCG interpretation of all of this before I go any further with
this, but like to get ideas from other folks out there who might have
covered this ground before.

Capt. Jeff