2013 Vessel General Permit (herein after, 2013VGP) for discharges of pollutants incidental to their normal operation of vessels has been enforced by the U.S. Environmental Protection Agency (herein after, EPA) since December 19, 2013.
It was notified that "ballast water numeric discharge limitations and implementation schedule of 2013VGP are aligned with that of USCG rules (refer to Technical Information TEC-0968)" and "USCG published the Policy letter regarding the provision to grant a method to make request of extension to the implementation schedule for ballast water management discharge standards for vessels using USCG approved ballast water management systems (refer to Technical Information TEC-0971)".

At this time, Enforcement Response Policy was published as attached, which shows that where USCG has granted an extension to the implementation schedule for ballast water management discharge standards for vessels using USCG approved ballast water management systems as provided in 33CFR151.1513 and 151.2036, that information will be considered by EPA.
Highlight of the Enforcement Response Policy is as following:

･ An extension granted by USCG to the implementation schedule for ballast water management system will be considered by EPA, and in that case, EPA will take into account conditions expressed in the USCG's extension letter (i.e. the vessel conducts complete ballast water exchange in an area 200 nautical miles from any shore prior to discharging ballast water in the waters of United States, adhere to the Coast Guard's ballast water management plan as well as to recordkeeping and reporting provisions).

And, additional information obtained by correspondence with EPA regarding application of 2013VGP is as following:

･ When a vessel discharges ballast water, bilgewater or graywater etc. at any time within 3 nm from shore, then they would need to comply with the applicable requirements in the 2013VGP , that is, when a vessel does not discharge ballast water, bilgewater or graywater etc. at any time while operating within 3 nm from shore, then the requirements do not apply, including the monitoring requirements for new build vessels in section 2.2.2.1 and 2.2.15.2 and the ballast water requirements in 2.2.3.5.1 of 2013 VGP

(To be continued)