JULY 2019 • FOGHORN 31 HOW PVA BENEFITS YOU publish these by December, 2020. At this time, EPA officials have suggested that “the future standards will be at least as stringent as existing EPA 2013 VGP requirements and will be technol- ogy based.” Next, the Coast Guard will continue this regulatory project by writing cor- responding compliance regulations for implementing the EPA rules and outlining enforcement. The Coast Guard has a deadline of two years following the completion of the EPA’s rules, and the Coast Guard’s rules may cover not only operational compliance but also “requirements governing the design, construction, testing, approval, installation, and use of devices to achieve the EPA national standards of performance” (primarily referencing ballast water treatment systems). Both the EPAand Coast Guard have been engaging in stakeholder outreach and engagement, hosting several online webinars and the in-person listening session over the past few months. The presentation slides from these events are available online at the EPA website www.epa.gov/vessels-marinas-and- ports/vessel-incidental-discharge-act- vida-engagement-opportunities. PVA will continue to participate in this regu- latory project every step of the way, on your behalf, and keep you informed as it progresses. n (Note: The Vessel General Permit for incidental discharges is a separate regulatory requirement of the Clean Water Act from the rules covering vessel discharge of treated sewage effluent. This distinction can sometimes be confusing. See Ed Welch’s column in this edition of FOGHORN for an update on the law governing treated sewage effluent discharge, including No Discharge Zones).