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On January 29, 2019 seven floating homes at the Grindstone Joe Association facility were red-tagged for a variety of violations, including unpermitted connections to shore-side septic, water, and electrical services, and unpermitted structures. At a meeting between our staff and representatives of the houseboat owners, a question was raised about what would be necessary to convert the floating homes to vessels, which would then not be subject to San Joaquin County building code and permitting requirements. The purpose of this letter is to outline the features that must be present so that the San Joaquin County Environmental Health Department and Community Development Department will not object that these structures to be vessels. After a review of the U.S. Supreme Court ruling in re: Lozman v. City of Riviera Beach, Florida, the California Health and Safety Code (Cal. Health & Safety Code Ann. §18075.55(d)), and the California Department of Motor Vehicles Regulations (CA Vehicle Code §§9840, 9871.5 and Harbors and Navigation Code §651), we have determined the features that must be present in order to consider the subject floating homes to be vessels are: The houseboats must be self-powered, which means that each of the houseboats must have a permanently available means of self-propulsion. This propulsion can be in the form of an outboard motor for each houseboat. The houseboats must have a means for steering. This may be achieved through the fitting of a steerable outboard motor or other rudder assembly with steerage. The houseboats must have onboard potable water storage. The houseboats must have a self-contained electrical system so that the electric functions aboard the houseboat can be operated and any electrical storage systems can be re-charged while the houseboat is not connected to shore power. This generation capability may be in the form of a self- contained generator, or a generator capability associated with the propulsion motor. The houseboats must have a U.S. Coast Guard approved marine toilet and black-water holding tank, and cannot have any permanent connection to a shore-side septic system. The houseboats must be either registered as vessels by the California Department of Motor Vehicles (i.e. issued a title, a CF Number and current tags), or documented as a vessel by the U.S. Coast Guard. We have determined that building permits are not required to make modifications to conform to the above requirements, however, the houseboats must be individually inspected by the San Joaquin Environmental Health Department before the violations can be cleared. Each houseboat owner will be responsible for updating the property classification for their houseboat with the San Joaquin County Tax Assessor.