(2:55 p.m. EDT) -- On June 16, Norwegian Cruise Line Holdings (NCLH) suspended all sailings  on its three brands through September 30, 2020, with one notable exception: Norwegian Cruise Line voyages to Alaska departing in September.

Norwegian is working to have the cruises, which would depart from Seattle aboard Norwegian Bliss and Norwegian Joy, go ahead as scheduled, with port calls including Juneau, Icy Strait Point, Skagway, Ketchikan and Victoria, British Columbia.

"We are hopeful that through the support of the Alaska delegation and openness of mayors of Alaska port towns, we have the potential to resume voyages in September," said Norwegian Cruise Line in a statement.

But with the 2020 Alaska cruise season decimated by rulings, regulations and the ongoing COVID-19 pandemic -- including a new initiative requiring negative COVID-19 PCR tests prior to arrival in the state -- it's hard to see a way for such sailings to take place. It begs the question: How likely are these September cruises to actually happen?

The Issue: The Passenger Vessel Services Act

Norwegian Bliss (Photo: Cruise Critic)
Because Norwegian Bliss and Norwegian Joy, like almost all of the world's large-ship cruise fleet, are foreign-flagged, they cannot operate closed-loop cruises roundtrip from a United States port without first stopping in a"distant foreign port" as mandated by the U.S. Passenger Vessel Services Act (PVSA).

For voyages out of Seattle to Alaska, that has always meant an evening service call in Victoria, British Columbia. But Transport Canada has banned cruises over 100 passengers from operating in Canadian waters until October 31, 2020.

That, in turn, renders these voyages legally unable to operate -- at least under current restrictions in place. Violating the PVSA results in a fine of $300 per person the vessel carries.

What About Redeploying Pride of America?

Ship Exterior on Pride of America
On the surface, Norwegian has a leg up on the rest of the cruise industry, thanks to the 2005-built Pride of America: the only large-scale, U.S.-flagged cruise ship in operation.

Built as part of Norwegian's NCL Hawaii arm that inaugurated year-round cruising from Honolulu in 2004 aboard the former Norwegian Sky -- temporarily renamed Pride of Aloha -- flagging the ship in the United States required a gargantuan amount of political and legal wrangling, as Pride of America was built in the United States but outfitted in Germany (technically a no-no as far as U.S. regulations go).

But with an American crew, would it be possible to redeploy Pride of America to Seattle to conduct cruise to Alaska, bypassing the need for a stop in the Canadian province of British Columbia?

No: Norwegian tells Cruise Critic that their agreement with the government over Pride of America requires that the ship sail only in Hawaii. Redeploying the vessel to the U.S. mainland is not an option.

Asking for An Exemption?

Ship Exterior on Pride of America
The rules and regulations within the PVSA have long been a sticking point with cruise lines, who would rather build cruise ships in foreign shipyards that have decades of experience in doing so, or design itineraries that don't require the stop in a foreign port.

But the law itself says that exemptions can only be made for"interests of national defense." Leisure cruising is unlikely to qualify.

Norwegian has, in the past, successfully apply for waivers to the PVSA in the early days of its Hawaii operations as NCL America, which allowed the foreign-built Norwegian Sky and Norwegian Jade (then named Pride of Hawaii) to operate under the U.S. flag until 2008, when the fleet was paired down to just Pride of America.

While it is unclear if exemptions could be secured prior to September, doing so for a single month worth of sailings seems unlikely -- unless it were part of a larger, long-term plan to run cruises from the U.S. mainland to U.S.-only ports of call; something Norwegian does have experience with thanks to its long-standing operations in Hawaii.

Cruise Critic reached out to Norwegian Cruise Line to see if the line has asked the federal government for an exemption to the PVSA. The company is not commenting or giving interviews on the subject.

Cruise Critic has also emailed the Alaska congressional delegation, which consists of Sen. Lisa Murkowski, Sen. Dan Sullivan and Representative Don Young, to see if they support an exemption. We'll update this story with their responses as they come in.

What the Ports Are Saying

Seattle Port
Cruise Critic is also checking with various ports, including the Greater Victoria Harbour Authority, the Port of Seattle, and CLIA's Alaska branch in Juneau. None would comment directly on Norwegian's plans to run cruises this September to Alaska from Seattle.

"Early in the 2020 season the Port made a commitment that the Seattle cruise season would not begin until the current COVID-19 related restrictions were lifted," said Port of Seattle Executive Director Stephen Metruck.

"In recent weeks, many of our cruise lines canceled their 2020 Seattle season while awaiting further direction from the U.S. Centers for Disease Control and Prevention.  While our current focus must be on public health, we look forward to the day when local and federal health authorities can declare the crisis over and the cruise industry rebounds robustly in support of local jobs, area businesses and full economic recovery."

Is Alaska a Reality This Year?

View of Glacier Bay from the Mini-Suite balcony on Norwegian Bliss
Regardless of whether the Alaska coalition and local authorities want these voyages to go forward, it will be the federal governments that determine what happens next.

Either Transport Canada rescinds the no-sail order, or the U.S. modifies the PVSA to either make an exemption for Norwegian Bliss and Norwegian Joy; or permit Pride of America to cruise to the mainland.

Cruise Critic will continue to monitor the situation and update this story as more information comes in.