Here is something I've been thinking about (or as my wife says , "another one of your stupid ideas").
Since it looks like a straight exemption is going to be hard to get and "boatels" never being sucessful, go to the Coast Guard and try to work out a compromise....suggest not running the boat at night instead tie her up at some city where the local fire department can help in case of emergency. In other words Her Majesty is an excursion boat for 12 hours and a hotel for 12 hours. Of course they would have to get an agreement with the fire department in whatever city was chosen and the Coast Guard would probably have to approve the arrangement. I'm sure whichever town was chosen for overnight visits would love having a couple of hundred money spending tourists and the local fire department would welcome any additional revenue the boat would pay them for their service.
OR...carry 49 overnight passengers and day time excursion passengers who be bused to a local hotel overnight. Probably this arrangement would bring the boat more revenue because in addition to 49 overnight passengers the boat could carry perhaps 300 day time excursionists.
In both the senerio's the boat couldn't tramp up and down the river it would be captive to one area stopping at just one or two cities. There is a business model already in place for this kind of operation....the TWILIGHT.
I would run trips like these out of New Orleans west to Cajun Country....with all the TV exposure the "swamp people" are getting these days there is a definite interest in this area of the county and the boat wouldn't be competing in the NOLA/Baton Rouge trade. Also the boat could operate year round.
But what do I know? or as my wife says "nothing"!