eNOAD Arrival Port or Place

For “Arrival time” on Coast Guard" eNOAD (electronic arrival and departure) I’ve always used the time at the berth. Last voyage however the agents instructed me to use the ETA at the pilot station instead.

Coast Guard G-PCV Policy Letter 06-05 says “Requiring arriving vessels to submit the NOA based on arrival a sea buoy or pilot station is not consistent with the CFR” The CFRs say arrival is where the vessel is “bound to anchor or moor”

The CFRs are not that clear but it seems the intention is that arrival is at the final intended destination within the port. Don’t know if the agents are giving me bad info.

Anyone have any experience or insight into this?