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RECEIVE ® APRAPR n Lehigh Hanson 0 5 20f2114'7 HEIDELBERGCLMENTGroup ENVIRONMENIAL HEALTH PERMIT/SERVICES Lehigh Hanson West Region 3000 Executive Parkway, Suite 240 San Ramon, CA 94583 Phone (510) 340-0762 March 30, 2017 San Joaquin County Environmental Health Department Attn: Linda Turkatte, Director 1868 E. Hazelton Ave. Stockton, CA 95205 Re: MIV Golden Arrow I (IMO No. 7007095) // inspection Dated March 14, 2017 // CERS ID 10729876 Dear Ms. Turkatte: We write to you today regarding the M/V Golden Arrow I (IMO No. 7007095), a Panama- flagged vessel (the "Vessel"), a vessel that is docked at the Port of Stockton and owned by Lehigh Southwest Cement Company ("Lehigh"). On March 14, 2017, Inspector Roberto Lopez from the San Joaquin County Environment Health Department ("County") boarded the Vessel and conducted an inspection of the Vessel and issued an inspection report ("Inspection Report") using the CERS ID 10729876. As you know, Lehigh also leases a facility located at 205 Port Road, Port of Stockton, California, CERS ID 10729876 (the "Facility") that the County regularly inspects. However, Mr. Lopez' s inspection did not include the Facility but focused only on the Vessel. The Facility and the Vessel are two separate and distinct locations, subject to separate and distinct laws and regulations. The Facility is comprised of the landside operations and equipment, and it is subject to U. S . domestic requirements, including federal, state, county, and local laws and regulations. The Vessel, on the other hand, is a foreign-flagged vessel subject to international law, including the International Maritime Organization ("IMO") conventions ratified by the United States, and certain U. S . federal law. Generally, under the federal preemption principle, the Vessel is not subject to state and local laws and regulations, including those that underlie the Inspection. Instead, the Vessel is required to comply with flag-state (Panama) laws and regulations, international standards, and conventions. T Vessel is subject to United States Coast Guard ("USCG") inspection and verification of comRliance with these standards and conventions. c The Vessel is flagged with the Panama Maritime Authority, classed with Russian Maritime Register of Shipping ("RS"), and otherwise compliant with applicable international and USCG requirements. As required by Panama and the U. S . , the Vessel is required to maintain its class requirements (i.e. , those requirements required by international law as validated by its elected classification society, RS) and comply with relevant federal laws, including USCG port state