Paso Robles City Council
August 18, 2026

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40 District, the Participants, and their respective departments experience multiple cybersecurity threats which include but are not limited to, social engineering, malware, denial-of-service and other attacks on endpoints.

The Flood Control District has put several preventive measures in place to safeguard against cybersecurity threats. These measures include cybersecurity awareness training, firewalls, email filtering, web content filtering, endpoint protection, and ensuring that operating systems, network equipment, and endpoint devices are up-to-date with the latest patches. Additionally, advanced segmentation and monitoring techniques are employed to detect and respond to potential threats within the network, while real-time endpoint detection and response systems help identify and mitigate any malicious activity on devices.

The Flood Control District relies in part on information technology infrastructure and cybersecurity services administered by the County, and a cybersecurity incident affecting County systems could also affect the Flood Control District’s operations. The Flood Control District currently maintains insurance coverage with respect to certain information security and privacy liability claims through the County’s insurance program. Nonetheless, future cybersecurity attacks could affect the operation and finances of the Flood Control District.

Each of the Participants also relies on complex digital networks and systems to conduct their operations, which are potentially subject to cybersecurity threats that may affect their operations and finances, including their ability to meet payment obligations under their respective Delivery Contracts. See the subheading “ –Cybersecurity” for each Participant in APPENDIX A–“THE PARTICIPANTS.”
Limited Liability of Authority to the Owners
Except as expressly provided in the Indenture, the Authority will not have any obligation or liability to the Owners of the 2026 Bonds with respect to the payments when due by the Flood Control District pursuant to the Pledge Agreement, or with respect to the performance by the Flood Control District of other agreements and covenants required to be performed by it contained in the Pledge Agreement, or with respect to the performance by the Trustee of any right or obligation required to be performed by it contained in the Indenture.

Changes in Law
There can be no assurance that the State Legislature will not at some future time enact legislation, or that the State electorate will not adopt initiatives or approve legislation amending the State Constitution, that could amend or create laws resulting in a reduction of moneys securing or available to pay the 2026 Bonds. Additionally, future initiative measures or other legislative actions may place further limitations on the ability of the State, the Participants or local districts to increase revenues or appropriations, which could affect the ability of the Participants to implement rate increases, reduce their ability to make payments under the respective Delivery Contracts and adversely affect the security for the 2026 Bonds.

CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS Described below are certain measures which have impacted or may in the future impact the Participants’ Capital Projects Installment Debt Service payments.

Article XIII A of the California Constitution
On June 6, 1978, California voters approved an amendment (commonly known as both Proposition 13 and the Jarvis-Gann Initiative) to the California Constitution. This amendment, which added Article XIII A to the California Constitution, among other things affects the valuation of real property for the purpose of taxation in that it defines the full cash property value to mean “the county assessor’s valuation of real property as shown on the 1975/76 tax bill under “full cash value,” or thereafter, the appraised value of real property newly constructed, or when a change in ownership has occurred after the 1975 assessment.” The full cash value may be adjusted annually to reflect inflation at a rate not to exceed 2% per year, or a reduction in the consumer price index or comparable local data at a rate not to exceed 2% per year, or reduced in the event of declining property value caused by damage, destruction or other factors including a general economic downturn. The amendment further limits the amount of any ad valorem tax on

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41 real property to 1% of the full cash value except that additional taxes may be levied to pay debt service on indebtedness approved by the voters prior to July 1, 1978, on bonded indebtedness for the acquisition or improvement of real property approved on or after July 1, 1978 by two-thirds of the votes cast by the voters voting on the proposition, and on bonded indebtedness for school facilities approved by 55% of the votes cast.

Legislation enacted by the California Legislature to implement Article XIII A provides that all taxable property is shown at full assessed value as described above. In conformity with this procedure, all taxable property value included in this Official Statement (except as noted) is shown at 100% of assessed value and all general tax rates reflect the $1 per $100 of taxable value. Tax rates for voter approved bonded indebtedness and pension liabilities are also applied to 100% of assessed value.

Future assessed valuation growth allowed under Article XIII A (new construction, change of ownership, 2% annual value growth) will be allocated on the basis of “sites” among the jurisdictions that serve the tax rate area within which the growth occurs. Local agencies and school districts will share the growth of “base” revenue from the tax rate area. Each year’s growth allocation becomes part of each agency’s allocation the following year. The County is unable to predict the nature or magnitude of future revenue sources which may be provided by the State to replace lost property tax revenues. Article XIII A effectively prohibits the levying of any other ad valorem property tax above the 1% limit except for taxes to support indebtedness approved by the voters as described above.

Article XIII A has been amended to permit reduction of the base year value in the event of declining property values caused by damage, destruction or other factors, and to provide that there would be no increase in the “base year value” in the event of reconstruction of property damaged or destroyed in a disaster if certain conditions are met, or in the event of certain transfers between parents and children, between grandparents and grandchildren, between spouses, or in certain situations where the elderly or disabled acquire new residences. If property values decline due to recessionary or other factors, the County may review the assessed values of properties. The State Revenue and Taxation Code permits county assessors who have reduced the assessed valuation of a property as a result of natural disasters, economic downturns or other factors, to subsequently “recapture” such value (up to the pre-decline value of the property) at an annual rate higher or lower than 2%, depending on the assessor’s measure of the restoration of value of the damaged property. The California courts have upheld the constitutionality of this procedure.

Article XIII B of the California Constitution
On November 6, 1979, California voters approved Proposition 4, the Gann Initiative, which added Article XIII B to the California Constitution. In June 1990, Article XIII B was amended by the voters through their approval of Proposition 111. Article XIII B of the California Constitution limits the annual appropriations of the State and any city, county, school district, authority or other political subdivision of the State to the level of appropriations for the prior fiscal year, as adjusted annually for changes in the cost of living, population and services rendered by the governmental entity. The “base year” for establishing such appropriation limit is the 1978-79 fiscal year. Increases in appropriations by a governmental entity are also permitted (i) if financial responsibility for providing services is transferred to the governmental entity, or (ii) for emergencies so long as the appropriations limits for the three years following the emergency are reduced to prevent any aggregate increase above the Constitutional limit. Decreases are required where responsibility for providing services is transferred from the government entity.

Appropriations subject to Article XIII B include generally any authorization to expend during the fiscal year the proceeds of taxes levied by the State or other entity of local government, exclusive of certain State subventions, refunds of taxes, benefit payments from retirement, unemployment insurance and disability insurance funds.

Appropriations subject to limitation pursuant to Article XIII B do not include debt service on indebtedness existing or legally authorized as of January l, 1979, on bonded indebtedness thereafter approved according to law by a vote of the electors of the issuing entity voting in an election for such purpose, appropriations required to comply with mandates of courts or the Federal government, appropriations for qualified outlay projects, and appropriations by the State of revenues derived from any increase in gasoline taxes and motor vehicle weight fees above January l, 1990 levels. “Proceeds of taxes” include, but are not limited to, all tax revenues and the proceeds to any entity of government from (i) regulatory licenses, user charges, and user fees to the extent such proceeds exceed the cost of providing the service or regulation, (ii) the investment of tax revenues and (iii) certain State subventions received by local governments. As amended by Proposition 111, the appropriations limit is tested over consecutive two-year periods. Any excess of the

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42 aggregate “proceeds of taxes” received by the County over such two-year period above the combined appropriations limits for those two years is to be returned to taxpayers by reductions in tax rates or fee schedules over the subsequent two years.

As amended in June 1990, the appropriations limit for the County in each year is based on the limit for the prior year, adjusted annually for changes in the costs of living and changes in population, and adjusted, where applicable, for transfer of financial responsibility of providing services to or from another unit of government. The change in the cost of living is, at the County’s option, either (i) the percentage change in California per capita personal income, or (ii) the percentage change in the local assessment roll for the jurisdiction due to the addition of nonresidential new construction. The measurement of change in population is a blended average of statewide overall population growth, and change in attendance at local school and community college (“K-14”) districts.

Article XIII B permits any government entity to change the appropriations limit by vote of the electorate in conformity with statutory and Constitutional voting requirements, but any such voter-approved change can only be effective for a maximum of four years.

Each Participant has advised that it is of the opinion that its charges for water service are not subject to the limits of Article XIII B. Each Participant covenants in its Delivery Contract that it will prescribe rates and charges sufficient to provide payment of its Capital Projects Installment Debt Service in each year. See APPENDIX A–”THE PARTICIPANTS.”
Article XIII C and Article XIII D of the California Constitution General. On November 5, 1996, the voters of the State approved Proposition 218, known as the “Right to Vote on Taxes Act.” Proposition 218 added Articles XIII C and XIII D to the California Constitution, which contain a number of provisions affecting the ability of cities and counties to levy and collect both existing and future taxes, assessments, fees and charges.

Article XIII C. Article XIII C provides that the initiative power shall not be prohibited or otherwise limited in matters of reducing or repealing any local tax, assessment, fee or charge and that the power of initiative to affect local taxes, assessments, fees and charges shall be applicable to all local governments. Article XIII C does not define the terms “local tax,” “assessment,” “fee” or “charge.” On July 24, 2006, the Supreme Court held in Bighorn-Desert View Water Agency v. Verjil that the provisions of Article XIII C applied to rates and fees charged for domestic water use. In that decision, the Court noted that the decision did not address whether an initiative to reduce fees and charges could override statutory rate setting obligations. In any event, the County and the Flood Control District do not believe that Article XIII C grants to the voters within the County the power to repeal or reduce rates and charges in a manner that would be inconsistent with the contractual obligations of the County. No assurance can be given that the voters of the County will not, in the future, approve initiatives which seek to repeal, reduce or prohibit the future imposition or increase of assessments, fees or charges, including the fees and charges.

The interpretation and application of Proposition 218 will likely be subject to further judicial determinations, and it is not possible at this time to predict with certainty the outcome of such determinations.

Article XIII D. Article XIII D established procedural requirements for the imposition of assessments, defined to mean any levy or charge upon real property for a special benefit conferred upon real property, including standby charges. The procedural requirements include the conducting of a public hearing and an election, by mailed ballot, with notice to the record owner of each parcel subject to the assessment. If a majority of the ballots returned oppose the assessment, it may not be imposed.

Article XIII D conditions the imposition or increase of any “fee” or “charge” upon there being no written majority protest after a required public hearing and, for fees and charges other than for sewer, water, refuse collection services or storm water, voter approval. Article XIII D defines “fee” or “charge” to mean levies (other than ad valorem or special taxes or assessments) imposed by a local government upon a parcel or upon a person as an incident of the ownership or tenancy of real property, including a user fee or charge for a “property-related service.” One of the requirements of Article XIII D is that before a property related fee or charge may be imposed or increased, a public

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43 hearing upon the proposed fee or charge must be held and mailed notice sent to the record owner of each identified parcel of land upon which the fee or charge is proposed for imposition. In the public hearing, if written protests of the proposed fee or charge are presented by a majority of the owners of affected identified parcel(s), an agency may not impose the fee or charge.

Article XIII D provides that nothing in Proposition 218 shall be construed to affect existing laws relating to the imposition of fees or charges as a condition of property development.

In Howard Jarvis Taxpayers Association v. City of Los Angeles, the Court of Appeal held that fees for water that are based upon metered amounts used are charges for a commodity and not related to property ownership and, consequently, Article XIII D does not apply to such fees. However, in a decision rendered in February 2004, the California Supreme Court in Richmond et al. v. Shasta Community Services District, 32 Cal. 4th 409, upheld a Court of Appeals decision that water connection fees were not property related fees or charges subject to Article XIII D, while at the same time stating in dicta that fees for ongoing water service through an existing connection were property related fees and charges. In October 2004, the California Supreme Court granted review of the decision of the Fourth District Court of Appeal in Bighorn-Desert View Water Agency v. Beringson, 120 Cal. App. 4th 891 (2004), in which the appellate court had relied on Howard Jarvis Taxpayers Association v. City of Los Angeles and rejected the Supreme Court’s dicta in Richmond et al. v. Shasta Community Services District. On March 23, 2005, the California Fifth District Court of Appeal published Howard Jarvis Taxpayers Association v. City of Fresno, 127 Cal.App.4th 914 (5th Dist. 2005), holding that an “in lieu” fee which is payable to the general fund of the City of Fresno from its water utility and which is included in the water rate structure of the city was invalid. In reaching its decision, the court concluded that the city’s water rates were “property related” fees, governed by the limitations of Article XIII D. The City of Fresno requested a review of this decision by the California Supreme Court, which denied review. On July 24, 2006, the Supreme Court ruled in Bighorn-Desert View Water Agency v. Verjil. In dicta, the Supreme Court repeated its previous dicta in Richmond et al. v. Shasta Community Services District that fees and charges for ongoing water service through an existing connection were property related fees and charges under Article XIII D.

In addition to the procedural requirements of Article XIII D, under Article XIII D all property related fees and charges, including those which were in existence prior to the passage of Proposition 218 in November 1996, must meet the following substantive standards: (i) the revenues derived from the fee or charge cannot exceed the funds required to provide the property-related service; (ii) the revenues derived from the fee or charge must not be used for any purpose other than that for which the fee or charge was imposed; (iii) the amount of a fee or charge imposed upon any parcel or person as an incident of property ownership must not exceed the proportional cost of the service attributable to the parcel; (iv) no fee or charge may be imposed for a service unless that service is actually used by, or immediately available to, the owner of the property in question, fees or charges based on potential or future use of a service are not permitted, and standby charges, whether characterized as charges or assessments, must be classified as assessments and cannot be imposed without compliance with Section 4 of Article XIII D (relating to assessments); and (v) no fee or charge may be imposed for general governmental services including, but not limited to, police, fire, ambulance or library services where the service is available to the public at large in substantially the same manner as it is to property owners.

On April 20, 2015, the California Fourth District Court of Appeal issued a decision in Capistrano Taxpayers Association, Inc. v. City of San Juan Capistrano, 235 Cal.App.4th 1493 (2015), holding that the City of San Juan Capistrano’s tiered water rates (or inclining block rates) that were in effect from February 1, 2010 through June 30, 2014 violated the requirement of Proposition 218 that a fee or charge for property-related services, such as water delivery, must be proportional to the cost of providing service. In interpreting Proposition 218, the Court of Appeal emphasized that tiered water rates, or inclining block rates, that go up progressively in relation to usage are compatible with Proposition 218. However, the court concluded that Article XIIID requires that each tier must reflect the actual costs of service for property owners falling in each of the tiers. The court further concluded that the city had the burden of proof to demonstrate compliance with Proposition 218 and that the city failed to meet its burden of proof in demonstrating that its tiered water rates corresponded to the actual costs of providing service to each tier.

In June 2021, a San Diego Superior Court ruled that Otay Water District failed to demonstrate that its tiered water rates were proportional to the cost of service attributable to each customer’s parcel, as required by Proposition 218. The Court specifically found that the rates were based on “non-cost objectives such as conservation”

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44 and that the record did not contain sufficient support for the peaking factors utilized to calculate demand and allocate costs to different tiers of usage. On appeal to the 4th District, the Court of Appeal affirmed the finding that the rates do not comply with Proposition 218. Specifically, the Court of Appeal determined that (1) the tiered pricing structure was based on generalized assumptions and industry standards, rather than customer-specific data; (2) Otay improperly set certain rate components based on conservation concerns, rather than cost; and (3) the rate structure disproportionately burdened single family residential customers with a tiered rate structure, while allowing commercial and irrigation customers to utilize uniform rates.

The Authority and the Flood Control District are unable to predict the impact of a successful repeal or reduction of water rates and charges charged by any Participant on the financial condition of such Participant or the ability of such Participant to perform its obligations under its Delivery Contract. Further, the Authority and the Flood Control District are unable to predict whether the repeal or reduction of the rates and charges of any Participant would be detrimental to or inconsistent with the contractual obligations of the respective Participant. One might assert that Article XIII C cannot grant the voters within the Participants’ service area the power to repeal or reduce rates and charges in a manner which would be inconsistent with the contractual obligations of the respective Participants, giving rise to an unconstitutional impairment of contract under the U.S. Constitution and the California Constitution.

However, there can be no assurance of the availability of particular remedies adequate to protect the beneficial owners of the Bonds. Remedies available to beneficial owners of the Bonds in the event of a default by the Participants are dependent upon judicial actions which are often subject to discretion and delay and could prove both expensive and time-consuming to obtain. In addition to the specific limitations on remedies contained in the applicable documents themselves, the rights and obligations of the Flood Control District and the Participants, respectively, under the Delivery Contracts are subject to bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws affecting creditors’ rights, to the application of equitable principles if equitable remedies are sought, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against public agencies in the State of California. The various opinions of counsel to be delivered with respect to such documents, including the opinion of Bond Counsel, the form of which is attached as Appendix E hereto, will be similarly qualified.

The foregoing discussion of Proposition 218 should not be considered an exhaustive or authoritative treatment of the issues.

Future Initiatives
Article XIII A, Article XIII B, Article XIII C and Article XIII D were adopted as measures that qualified for the ballot through California’s initiative process. From time to time, other initiative measures could be adopted, which may place further limitations on the ability of the State, the County or local districts to increase revenues or to increase appropriations which may affect the County’s revenues or its ability to expend its revenues.

FINANCIAL STATEMENTS
Each of Paso Robles, SLO, and Templeton has provided its audited financial statements as of the fiscal year ended June 30, 2025, and for the fiscal year ended April 30, 2025 in the case of the Atascadero Mutual Water Company. See APPENDIX A–“THE PARTICIPANTS.” No auditor has reviewed or audited this Official Statement, or undertaken procedures to consent to the inclusion of its report with respect to any of the financial statements.

CONTINUING DISCLOSURE
The Authority has determined that no financial or operating data concerning the Authority is material to any decision to purchase, hold, or sell the 2026 Bonds and the Authority will not provide such information.

Flood Control District
The Flood Control District will enter into a Continuing Disclosure Agreement with Digital Assurance Certification, L.L.C., as dissemination agent to the Flood Control District, to be dated the date of delivery of the 2026 Bonds. The Flood Control District, covenants for the benefit of the beneficial owners of the 2026 Bonds to provide certain financial information and operating data relating to the Flood Control District by no later than March 31 each

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45 year commencing with the report due on March 31, 2027 for the Fiscal Year ended June 30, 2026 (each a “Flood Control District Annual Report”), and to provide notices of the occurrence of certain specified events. The Flood Control District Annual Report and notices of specified events will be filed by the Flood Control District or the dissemination agent to the Flood Control District, through the EMMA site which is maintained by the MSRB. Copies of the Flood Control District Annual Reports and notices of specified events since June 1, 2009 are available on the EMMA site. These covenants have been made in order to assist the Underwriter in complying with Securities and Exchange Commission Rule 15c2-12(b)(5) promulgated under the Securities Exchange Act of 1934 (the “Rule”). The specific nature of the financial information and operating data and the notices of specified events is set forth in APPENDIX D – “FORMS OF CONTINUING DISCLOSURE AGREEMENTS–SAN LUIS OBISPO COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT CONTINUING DISCLOSURE AGREEMENT.” During the past five years, due to an administrative error, the County’s Annual Comprehensive Financial Report for the Fiscal Year ended June 30, 2023, which was referenced in the 2023 Flood Control District Annual Report, was not correctly posted, notwithstanding its timely filing. The County also failed to include certain required information in its annual report for the Fiscal Year ended June 30, 2022 and failed to timely file a notice of incurrence of a financial obligation. All such filings have since been remedied.

The Participants
Each Participant has covenanted to provide certain financial and operating data relating to such Participant by no later than nine months following the end of the respective fiscal year of each Participant commencing with the report due in 2027 for its respective fiscal year ended in 2026 (each a “Participant Annual Report”). Each Participant Annual Report will be filed by the Participant or the Flood Control District, as dissemination agent to each Participant, through EMMA. The fiscal year-end for AMWC is April 30, and the fiscal year-end for Paso Robles, SLO and Templeton is June 30. The specific nature of the financial and operating data to be provided is set forth in APPENDIX D– “FORMS OF CONTINUING DISCLOSURE AGREEMENTS–PARTICIPANTS CONTINUING DISCLOSURE AGREEMENTS.”
AMWC. During the past five years, AMWC has not failed to comply in all material respects with its prior continuing disclosure obligations entered into in connection with the Rule.

Paso Robles. During the past five years, Paso Robles has not failed to comply in all material respects with its prior continuing disclosure obligations entered into in connection with the Rule.

SLO. During the past five years, SLO has from time to time failed to link certain CUSIP numbers to its timely filed audited financial statements. Such errors have been corrected.

Templeton. During the past five years, Templeton has not failed to comply in all material respects with its prior continuing disclosure obligations entered into in connection with the Rule.

TAX MATTERS
General. The delivery of the 2026 Bonds is subject to delivery of the opinion of Bond Counsel, to the effect that interest on the 2026 Bonds for federal income tax purposes under existing statutes, regulations, published rulings, and court decisions (1) will be excludable from the gross income, as defined in section 61 of the Internal Revenue Code of 1986, as amended to the date of initial delivery of the 2026 Bonds (the “Code”), of the owners thereof pursuant to section 103 of the Code, and (2) will not be included in computing the alternative minimum taxable income of the owners thereof who are individuals. The delivery of the 2026 Bonds are also subject to the delivery of the opinion of Bond Counsel, based upon existing provisions of the laws of the State of California that interest on the 2026 Bonds is exempt from personal income taxes of the State of California. The form of Bond Counsel’s anticipated opinion regarding the 2026 Bonds is included as Appendix E. The statutes, regulations, rulings, and court decisions on which such opinions will be based are subject to change.

In rendering the foregoing opinions, Bond Counsel will rely upon the representations and certifications of the Authority and the Flood Control District made in a certificate of even date with the initial delivery of the 2026

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46 Bonds pertaining to the use, expenditure, and investment of the proceeds of the 2026 Bonds (the “Tax Certificate”) and will assume continuing compliance with the provisions of the Indenture by the Authority and the Flood Control District subsequent to the issuance of the 2026 Bonds. The Indenture and the Tax Certificate contain covenants by the Authority and the Flood Control District with respect to, among other matters, the use of the proceeds of the 2026 Bonds and the facilities and equipment financed or refinanced therewith by persons other than state or local governmental units, the manner in which the proceeds of the 2026 Bonds are to be invested, the calculation and payment to the United States Treasury of any “arbitrage profits” and the reporting of certain information to the United States Treasury. Failure to comply with any of these covenants may cause interest on the 2026 Bonds to be includable in the gross income of the owners thereof from the date of the issuance of the 2026 Bonds.

Except as described above, Bond Counsel will express no other opinion with respect to any other federal, State or local tax consequences under present law, or proposed legislation, resulting from the receipt or accrual of interest on, or the acquisition or disposition of, the 2026 Bonds. Prospective purchasers of the 2026 Bonds should be aware that the ownership of tax-exempt obligations such as the 2026 Bonds may result in collateral federal tax consequences to, among others, financial institutions, life insurance companies, property and casualty insurance companies, S corporations with subchapter C earnings and profits, certain foreign corporations doing business in the United States, individual recipients of Social Security or Railroad Retirement benefits, corporations subject to the alternative minimum tax on adjusted financial statement income, individuals otherwise qualifying for the earned income tax credit, owners of an interest in a financial asset securitization investment trust (“FASIT”), and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry, or who have paid or incurred certain expenses allocable to, tax-exempt obligations. Prospective purchasers should consult their own tax advisors as to the applicability of these consequences to their particular circumstances.

Bond Counsel’s opinion is not a guarantee of a result, but represents its legal judgment based upon its review of existing statutes, regulations, published rulings and court decisions and the representations and covenants of the Authority and the Flood Control District described above. No ruling has been sought from the Internal Revenue Service (the “IRS”) or the State of California with respect to the matters addressed in the opinion of Bond Counsel, and Bond Counsel’s opinion is not binding on the IRS or the State of California. The IRS has an ongoing program of auditing the tax-exempt status of the interest on municipal obligations. If an audit of the 2026 Bonds is commenced, under current procedures, the IRS is likely to treat the Authority as the “taxpayer,” and the owners of the 2026 Bonds would have no right to participate in the audit process. In responding to or defending an audit of the tax-exempt status of the interest on the 2026 Bonds, the Authority may have different or conflicting interests from the owners of the 2026 Bonds. Public awareness of any future audit of the 2026 Bonds could adversely affect the value and liquidity of the 2026 Bonds during the pendency of the audit, regardless of its ultimate outcome.

For taxable years beginning after 2022, the Code imposes a minimum tax of 15 percent of the adjusted financial statement income of certain large corporations, generally consisting of corporations (other than S corporations, regulated investment companies and real estate investment trusts) with more than $1 billion in average annual adjusted financial statement income, determined over a three-year period. For this purpose, adjusted financial statement income generally consists of the net income or loss of the taxpayer set forth on the taxpayer’s applicable financial statement for the taxable year, subject to various adjustments, but is not reduced for interest earned on taxexempt obligations, such as the 2026 Bonds. Prospective purchasers that could be subject to this minimum tax should consult with their own tax advisors regarding the potential impact of owning the 2026 Bonds.

Existing law may change to reduce or eliminate the benefit to bond or note holders of the exclusion of interest on the 2026 Bonds from gross income for federal income tax purposes. Any proposed legislation or administrative action, whether or not taken, could also affect the value and marketability of the 2026 Bonds. Prospective purchasers of the 2026 Bonds should consult with their own tax advisors with respect to any proposed or future changes in tax law.

Tax Accounting Treatment of Discount and Premium on Certain 2026 Bonds.

The initial public offering price of certain 2026 Bonds (the “Discount 2026 Bonds”) may be less than the amount payable on such 2026 Bonds at maturity. An amount equal to the difference between the initial public offering price of a Discount 2026 Bond (assuming that a substantial amount of the Discount 2026 Bonds of that maturity are

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47 sold to the public at such price) and the amount payable at maturity constitutes original issue discount to the initial purchaser of such Discount 2026 Bond. A portion of such original issue discount allocable to the holding period of such Discount 2026 Bond by the initial purchaser will, upon the disposition of such Discount 2026 Bond (including by reason of its payment at maturity), be treated as interest excludable from gross income, rather than as taxable gain, for federal income tax purposes, on the same terms and conditions as those for other interest on the 2026 Bonds described above. Such interest is considered to be accrued actuarially in accordance with the constant interest method over the life of a Discount 2026 Bond, taking into account the semiannual compounding of accrued interest, at the yield to maturity on such Discount 2026 Bond and generally will be allocated to an initial purchaser in a different amount from the amount of the payment denominated as interest actually received by the initial purchaser during the tax year.

However, such interest may be required to be taken into account in determining the amount of the branch profits tax applicable to certain foreign corporations doing business in the United States, even though there will not be a corresponding cash payment. In addition, the accrual of such interest may result in certain other collateral federal income tax consequences to, among others, financial institutions, life insurance companies, property and casualty insurance companies, S corporations with subchapter C earnings and profits, individual recipients of Social Security or Railroad Retirement benefits, corporations subject to the alternative minimum tax on adjusted financial statement income, individuals otherwise qualifying for the earned income tax credit, owners of an interest in a FASIT, and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry, or who have paid or incurred certain expenses allocable to, tax-exempt obligations. Moreover, in the event of the redemption, sale or other taxable disposition of a Discount 2026 Bond by the initial owner prior to maturity, the amount realized by such owner in excess of the basis of such Discount 2026 Bond in the hands of such owner (adjusted upward by the portion of the original issue discount allocable to the period for which such Discount 2026 Bond was held) is includable in gross income.

Owners of Discount 2026 Bonds should consult with their own tax advisors with respect to the determination of accrued original issue discount on Discount 2026 Bonds for federal income tax purposes and with respect to the state and local tax consequences of owning and disposing of Discount 2026 Bonds. It is possible that, under applicable provisions governing determination of state and local income taxes, accrued interest on Discount 2026 Bonds may be deemed to be received in the year of accrual even though there will not be a corresponding cash payment.

The purchase price of certain 2026 Bonds (the “Premium 2026 Bonds”) paid by an owner may be greater than the amount payable on such 2026 Bonds at maturity. An amount equal to the excess of a purchaser’s tax basis in a Premium 2026 Bond and the amount payable at maturity constitutes premium to such purchaser. The basis for federal income tax purposes of a Premium 2026 Bond in the hands of such initial purchaser must be reduced each year by the amortizable bond premium, although no federal income tax deduction is allowed as a result of such reduction in basis for amortizable bond premium. Such reduction in basis will increase the amount of any gain (or decrease the amount of any loss) to be recognized for federal income tax purposes upon a sale or other taxable disposition of a Premium 2026 Bond. The amount of premium which is amortizable each year by a purchaser is determined by using such purchaser’s yield to maturity (or, in some cases with respect to a callable 2026 Bond, the yield based on a call date that results in the lowest yield on the 2026 Bond).

Purchasers of the Premium 2026 Bonds should consult with their own tax advisors with respect to the determination of amortizable bond premium with respect to the Premium 2026 Bonds for federal income purposes and with respect to the state and local tax consequences of owning and disposing of Premium 2026 Bonds.

LITIGATION
Steinbeck Vineyards and Eidemiller
The County, the Flood Control District, CSA-16-1, Paso Robles, AMWC, San Miguel Community Services District (“SMCSD”), and Templeton were named as a defendants in two lawsuits: Steinbeck et al v. County of San Luis Obispo et al (Santa Clara Superior Court Case No. 1-14-cv-265039) and Eidemiller v. County of San Luis Obispo (Santa Clara Superior Court Case No. 1-14-cv-269212) filed by landowners who claim superior overlying groundwater water rights as against the water supplier defendants. As of the date of this Official Statement, the two

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48 cases have been consolidated and the Court has divided the case into six phases. Phase 1 concerned plaintiffs’ prima facie case for quiet title, and the Court ruled that plaintiffs met their prima facie burden by proving that they each owned land within the watershed, thereby shifting the burden to defendants to prove their affirmative defenses (e.g. basin boundaries, prescription, treaty rights and pueblo rights). Phase 2 concerned basin boundaries, including AMWC and Templeton’s affirmative defense that they are located within a separate groundwater basin and a determination of the relevant exterior boundary of the basin. In this Phase, the Court ruled that AMWC and Templeton failed to prove that they pump groundwater from a basin separate from the main basin (i.e. the basin identified by the Department of Water Resources (DWR) in Bulletin 118 as the Paso Robles Area Subbasin (3-004.06)), and signed an order approving a stipulation by the parties that the boundary of the basin at issue is the outermost exterior boundary line as identified by DWR in Bulletin 118, i.e. the outermost exterior boundary line for the Paso Robles Area Subbasin (3-004.06) and the Atascadero Area Subbasin (3-004.11), recently recognized as a separate subbasin by DWR. Phase 3 concerned defendants’ (excluding AMWC who claims to be an overlying user and the Flood Control District who does not pump groundwater) affirmative defense of prescription (i.e. that they possess prescriptive water rights as against plaintiffs within the basin). In this Phase, a jury found that each of the defendants perfected their respective prescriptive groundwater rights during the years from 1981 to 1990 (the prescriptive period). Phase 4 concerned quantification of defendants’ prescriptive rights during the prescriptive period. In this Phase, the Court entered an order quantifying defendants’ prescriptive groundwater rights as follows: 1,267.70 acre-feet per year (AFY) for Paso Robles, 310 AFY for the County, 177.03 AFY for San Miguel and 308.9 AFY for Templeton. Phase 5 concerned defendants’ claim that they exercised self-help pumping during the prescriptive period. In this Phase, while the court did find that many plaintiffs met their burden of proving self-help pumping (on or around 425 parcels out of the total 754 plaintiff parcels), the Court also stressed the limitations of the ruling—e.g. the current action is not one to quantify rights or allocate pumping rights or to create a physical solution. The anticipated last phase (Phase 6) concerns SMCSD’s pueblo and treaty rights (Paso Robles recently withdrew these affirmative defenses), and trial is scheduled to commence on August 17, 2026, assuming plaintiffs’ motion for summary judgment (scheduled for hearing on July 15, 2026) is unsuccessful.

The Flood Control District does not believe that the resolution of this litigation will have a material adverse effect on the payments to be received from the affected Participants pursuant to the Delivery Contracts or the ability of the Authority to make payments, when due, on the 2026 Bonds.

Authority and Flood Control District
At the time of delivery of the 2026 Bonds, County Counsel, as Counsel to the Authority and to the Flood Control District will deliver opinions to the initial Underwriter that there is no controversy or litigation now pending against the Authority or the Flood Control District or, to the knowledge of their officers, threatened, concerning the validity of the 2026 Bonds, the Master Water Contract, the pledge of Revenues, the Indenture, the Pledge Agreement, the Delivery Contracts or any other document relating to the 2026 Bonds to which the Authority, the Flood Control District, or any Participant is or will become a party, or the performance by any of the Authority, the Flood Control District, or any Participant of its respective obligations thereunder; or to restrain or enjoin the execution and delivery of the Indenture, or the Continuing Disclosure Agreement; or in any way contesting or affecting the validity of the 2026 Bonds.

Participants
At the time of delivery of the 2026 Bonds, each Participant will deliver a certificate that there is no controversy or litigation now pending against such Participant, or to the knowledge of their officers, threatened, concerning the validity of the 2026 Bonds, the pledge of Water Revenues, the Pledge Agreement, the Delivery Contracts or any other document relating to the 2026 Bonds to which such Participant is or will become a party, or the performance by the Participant of its respective obligations thereunder; or to restrain or enjoin the execution and delivery of its Continuing Disclosure Agreement.

LEGAL MATTERS
Norton Rose Fulbright US LLP, Los Angeles, California, Bond Counsel, will render an opinion with respect to the validity of the 2026 Bonds. The form of the legal opinion proposed to be delivered by Bond Counsel is included as APPENDIX E to this Official Statement. Bond Counsel undertakes no responsibility for the accuracy,

Attachment 2
49 completeness, or fairness of this Official Statement. Certain legal matters will be passed upon for the Authority and the Flood Control District by County Counsel, for the Underwriter by Anzel Galvan LLP, San Francisco, California, Underwriter’s Counsel, for AMWC by [_____], [_____], California, for Paso Robles by [the Paso Robles City Attorney], for the City of San Luis Obispo by the [San Luis Obispo City Attorney], and for the Templeton Community Services District by [District Counsel].

Compensation paid to Bond Counsel and Underwriter’s Counsel is contingent on the delivery of the 2026 Bonds.

MUNICIPAL ADVISOR
The Authority has retained KNN Public Finance LLC, Berkeley, California, as Municipal Advisor, in connection with the authorization and delivery of the 2026 Bonds. The Municipal Advisor is not obligated to undertake, and has not undertaken to make, an independent verification or to assume responsibility for the accuracy, completeness or fairness of the information contained in this Official Statement. The Municipal Advisor is an independent advisory service and is not engaged in underwriting or trading of securities. The Municipal Advisor will receive compensation that is contingent upon the sale, issuance and delivery of the 2026 Bonds.

RATINGS
S&P Global Ratings (“S&P”) has assigned an [underlying rating of “[_____]” and an insured rating of “[_____]” to the 2026 Bonds with the understanding that the Bond Insurance Policy will be issued by the 2026 Insurer concurrently with the delivery of the 2026 Bonds]. [See “BOND INSURANCE” and APPENDIX G–”SPECIMEN MUNICIPAL BOND INSURANCE POLICY.”]
Any explanation of the significance of such ratings may only be obtained from the rating agency furnishing the same. The Authority furnished to S&P certain information and materials concerning the 2026 Bonds and the Flood Control District. Generally, rating agencies base their ratings on such information and materials and on investigations, studies and assumptions made by the rating agencies themselves. There is no assurance that any rating assigned to the 2026 Bonds by a rating agency will be maintained for any given period of time or that it will not be lowered or withdrawn entirely by such rating agency if in its judgment circumstances so warrant. Any downward revision or withdrawal of such rating may have an adverse effect on the market price or marketability of the 2026 Bonds.

UNDERWRITING
Loop Capital Markets LLC (the “Underwriter”), has agreed, subject to certain conditions precedent, to purchase the 2026 Bonds from the Authority pursuant to the terms and condition of a bond purchase agreement between the Authority and the Underwriter.

The 2026 Bonds may be offered and sold to certain dealers and others at prices lower than the offering prices stated on the inside cover hereof. The offering prices may be changed from time to time.

The Underwriter has agreed to purchase the 2026 Bonds at a purchase price equal to $_____, which represents the par amount of the 2026 Bonds, plus a [net] original issue premium in the amount of $_____, less an Underwriter’s discount in the amount of $_____. The bond purchase agreement relating to the 2026 Bonds provides that the Underwriter will purchase all of the 2026 Bonds if any are purchased, the obligation to make such purchase being subject to certain terms and conditions set forth in said bond purchase agreement, the approval of certain legal matters by counsel and certain other conditions.

MISCELLANEOUS
The foregoing and subsequent summaries or descriptions of provisions of the 2026 Bonds and the Indenture and all references to other materials not purporting to be quoted in full, are only brief outlines of some of the provisions thereof. Reference is made to said documents for full and complete statements of the provisions of such documents.

The appendices attached hereto are a part of this Official Statement.

Attachment 2
50 Copies, in reasonable quantity, of the Indenture, the Pledge Agreement, and the Delivery Contracts may be obtained upon request to the principal corporate trust office of the Trustee.

The execution and delivery of this Official Statement has been duly authorized by the County.

SLO COUNTY FINANCING AUTHORITY
By:

Chair of the Board of Commissioners

Attachment 2
A-1

APPENDIX A

THE PARTICIPANTS

Attachment 2
B-1

APPENDIX B

THE DELIVERY CONTRACTS

Attachment 2
C-1

APPENDIX C

FORMS OF PRINCIPAL LEGAL DOCUMENTS

Attachment 2
D-1

APPENDIX D

FORMS OF CONTINUING DISCLOSURE AGREEMENTS

Attachment 2
E-1

APPENDIX E

PROPOSED FORM OF BOND COUNSEL OPINION
[Closing Date]
SLO County Financing Authority
County Government Center
1055 Monterey Street
San Luis Obispo, California 93408
Re: $[PAR] SLO County Financing Authority (County of San Luis Obispo, California) Nacimiento Water Project Revenue Refunding Bonds, 2026 Series A
Ladies and Gentlemen:

We have acted as Bond Counsel to the SLO County Financing Authority (the “Authority”) in connection with the issuance by the Authority of its $[PAR] SLO County Financing Authority (County of San Luis Obispo, California) Nacimiento Water Project Revenue Refunding Bonds, 2026 Series A (the “2026 Bonds”). The 2026 Bonds are being issued under the provisions of the Marks-Roos Local Bond Pooling Act of 1985, constituting Article 4 of Chapter 5 of Division 7 of Title 1 (commencing with Section 6584) of the California Government Code and other applicable law (the “Bond Law”), and pursuant to an Indenture of Trust, dated as of September 1, 2007 (the “Original Indenture”), as supplemented by the First Supplemental Indenture, dated as of August 1, 2015 (the “First Supplemental Indenture”), the Second Supplemental Indenture, dated as of April 1, 2018 (the “Second Supplemental Indenture”) and the Third Supplemental Indenture, dated as of [October 1], 2026 (the “Third Supplemental Indenture” and, collectively with the Original Indenture, the First Supplemental Indenture and the Second Supplemental Indenture, the “Indenture”), each by and between the Authority and U.S. Bank Trust Company, National Association, as successor trustee (the “Trustee”).

The 2026 Bonds are limited obligations of the Authority secured under the Indenture by a pledge of Revenues and certain other moneys held under the Indenture. The Revenues consist of (a) all amounts derived from the Pledge Agreement, dated as of September 1, 2007 (the “Pledge Agreement”), by and between the San Luis Obispo County Flood Control and Water Conservation District (the “Flood Control District”) and the Authority, and (b) investment income with respect to the funds and accounts established under the Indenture, except for investment earnings on the Rebate Fund.

As Bond Counsel, we have reviewed and rely upon the Indenture and certifications of the Authority, the Flood Control District, the Trustee and others, opinions of counsel to the Authority, the Flood Control District and the Trustee, and such other documents, opinions and instruments as we deemed necessary to render the opinions set forth herein.

Capitalized terms used and not otherwise defined herein shall have the meanings ascribed thereto in the Indenture.

Based upon the foregoing, we are of the opinion that:

1. The 2026 Bonds constitute valid and binding limited obligations of the Authority as provided in the Indenture, and are entitled to the benefits of the Indenture.

2. The Indenture has been duly and validly authorized, executed and delivered by the Authority and, assuming the enforceability thereof against the Trustee, constitutes the legally valid and binding obligation of the Authority, enforceable against the Authority in accordance with its terms. The Indenture creates a valid pledge, to secure the payment of principal of and interest on the 2026 Bonds, of the Revenues and certain other amounts held by the Trustee in certain funds and accounts established pursuant to the Indenture, subject to the provisions of the Indenture permitting the application thereof for other purposes and on the terms and conditions set forth therein.

Attachment 2
E-2

3. It is further our opinion, based upon the foregoing, that pursuant to section 103 of the Internal Revenue Code of 1986, as amended and in effect on the date hereof (the “Code”), and existing regulations, published rulings, and court decisions thereunder, and assuming continuing compliance with the provisions of the Indenture and the Tax Certificate and in reliance upon the representations and certifications of the Authority and the Flood Control District made in the Tax Certificate of even date herewith pertaining to the use, expenditure, and investment of the proceeds of the 2026 Bonds, when the 2026 Bonds are delivered to and paid for by the initial purchasers thereof, interest on the 2026 Bonds for federal income tax purposes (1) will be excludable from the gross income, as defined in section 61 of the Code, of the owners thereof, and (2) will not be included in computing the alternative minimum taxable income of the owners thereof who are individuals.

In our opinion, under existing law, interest on the 2026 Bonds is exempt from personal income taxes of the State of California.

We express no other opinion with respect to any other federal, state, or local tax consequences under present law or any proposed legislation resulting from the receipt or accrual of interest on, or the acquisition or disposition of, the 2026 Bonds. Ownership of tax-exempt obligations such as the 2026 Bonds may result in collateral federal tax consequences to, among others, financial institutions, life insurance companies, property and casualty insurance companies, certain S corporations with subchapter C earnings and profits, certain foreign corporations doing business in the United States, corporations subject to the alternative minimum tax on adjusted financial statement income, owners of an interest in a financial asset securitization investment trust, individuals otherwise qualifying for the earned income tax credit, individual recipients of Social Security or Railroad Retirement benefits, and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry, or who have paid or incurred certain expenses allocable to, tax-exempt obligations.

The opinions expressed in paragraphs 1 and 2 above are qualified to the extent the enforceability of the 2026 Bonds and the Indenture may be limited by applicable bankruptcy, insolvency, debt adjustment, reorganization, moratorium or similar laws or equitable principles relating to or limiting creditors’ rights generally or as to the availability of any particular remedy. The enforceability of the 2026 Bonds and the Indenture is subject to the effect of general principles of equity, including, without limitation, concepts of materiality, reasonableness, good faith and fair dealing, to the possible unavailability of specific performance or injunctive relief, regardless of whether considered in a proceeding in equity or at law, and to the limitations on legal remedies against governmental entities in California. No opinion is expressed herein on the accuracy, completeness or fairness of the Official Statement or other offering material relating to the 2026 Bonds.

Our opinions are based on existing law, which is subject to change. Such opinions are further based on our knowledge of facts as of the date hereof. We assume no duty to update or supplement our opinions to reflect any facts or circumstances that may thereafter come to our attention or to reflect any changes in any law that may thereafter occur or become effective. Moreover, our opinions are not a guarantee of result and are not binding on the Internal Revenue Service or the State of California; rather, such opinions represent our legal judgment based upon our review of existing law that we deem relevant to such opinions and in reliance upon the representations and covenants referenced above.

Respectfully submitted,

Attachment 2
F-1

APPENDIX F

DTC AND THE BOOK-ENTRY ONLY SYSTEM
The information in this Appendix F concerning The Depository Trust Company, New York, New York (“DTC”), and DTC’s book-entry system has been obtained from DTC and the Authority and the Flood Control District take no responsibility for the completeness or accuracy thereof. The Authority and the Flood Control District cannot and do not give any assurances that DTC, Direct Participants (as defined below) or Indirect Participants (as defined below) will distribute to the Beneficial Owners (a) payments of interest, principal or premium, if any, with respect to the 2026 Bonds, (b) certificates representing ownership interest in or other confirmation of ownership interest in the 2026 Bonds, or (c) redemption or other notices sent to DTC or Cede & Co., its nominee, as the registered owner of the Bonds, or that they will do so on a timely basis, or that DTC, Direct Participants or Indirect Participants will act in the manner described in this Appendix F. The Authority and the Flood Control District are not responsible or liable for the failure of DTC or any DTC Direct or Indirect Participant to make any payment or give any notice to a Beneficial Owner with respect to the 2026 Bonds or an error or delay relating thereto. The current “Rules” applicable to DTC are on file with the Securities and Exchange Commission and the current “Procedures” of DTC to be followed in dealing with DTC’s Direct and Indirect Participants are on file with DTC.

The Depository Trust Company (“DTC”) will act as securities depository for the 2026 Bonds. The 2026 Bonds will be issued as fully-registered securities registered in the name of Cede & Co. (DTC’s partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully-registered 2026 Bond certificate will be issued in the aggregate principal amount of each maturity of the 2026 Bonds, and will be deposited with DTC.

DTC, the world’s largest securities depository, is a limited-purpose trust company organized under the New York Banking Law, a “banking organization” within the meaning of the New York Banking Law, a member of the Federal Reserve System, a “clearing corporation” within the meaning of the New York Uniform Commercial Code, and a “clearing agency” registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934, as amended. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC’s participants (“Direct Participants”) deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book-entry transfers and pledges between Direct Participants’ accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation (“DTCC”). DTCC is the holding company of DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly (“Indirect Participants”). DTC has a Standard & Poor’s rating of AA+. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com.

Purchases of 2026 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the 2026 Bonds on DTC’s records. The ownership interest of each actual purchaser of each 2026 Bond (“Beneficial Owner”) is in turn to be recorded on the Direct and Indirect Participants’ records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the 2026 Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their beneficial ownership interests in the 2026 Bonds, except in the event that use of the book-entry system for the 2026 Bonds is discontinued.

Attachment 2
F-2
To facilitate subsequent transfers, all 2026 Bonds deposited by Direct Participants with DTC are registered in the name of DTC’s partnership nominee, Cede & Co. or such other name as may be requested by an authorized representative of DTC. The deposit of 2026 Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the 2026 Bonds; DTC’s records reflect only the identity of the Direct Participants to whose accounts such 2026 Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers.

Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time.

Beneficial Owners of 2026 Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the 2026 Bonds, such as redemptions, defaults, and proposed amendments to the 2026 Bond documents. For example, Beneficial Owners of 2026 Bonds may wish to ascertain that the nominee holding the 2026 Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the Trustee and request that copies of notices be provided directly to them.

Redemption notices shall be sent to DTC. If less than all of the 2026 Bonds within a maturity are being redeemed, DTC’s practice is to determine by lot the amount of the interest of each Direct Participant in each issue to be redeemed.

Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to the 2026 Bonds unless authorized by a Direct Participant in accordance with DTC’s Money Market Instrument Procedures.

Under its usual procedures, DTC mails an Omnibus Proxy to the Authority as soon as possible after the record date.

The Omnibus Proxy assigns Cede & Co.’s consenting or voting rights to those Direct Participants to whose accounts 2026 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy).

Principal, premium, redemption proceeds, and interest payments on the 2026 Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC’s practice is to credit Direct Participants’ accounts upon DTC’s receipt of funds and corresponding detail information from the Authority or the Trustee, on a payment date in accordance with their respective holdings shown on DTC’s records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in “street name,” and will be the responsibility of such Participants and not of DTC nor of its nominee, the Trustee or the Authority, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of principal, premium, redemption proceeds, and interest to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the Authority or the Trustee, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants.

DTC may discontinue providing its services as depository with respect to the 2026 Bonds at any time by giving reasonable notice to the Authority or the Trustee. Under such circumstances, in the event that a successor securities depository is not obtained, 2026 Bond certificates are required to be printed and delivered.

The Authority may decide to discontinue use of the system of book-entry only transfers through DTC (or a successor securities depository). In that event, 2026 Bond certificates will be printed and delivered to DTC.

The information in this section concerning DTC and DTC’s book-entry system has been provided by DTC, and neither the Authority, the Flood Control District nor the Trustee take any responsibility for the accuracy thereof.

The Authority, the Flood Control District and the Underwriter cannot and do not give any assurances that DTC will distribute to Participants or that Participants or others will distribute to the Beneficial Owners payments of principal of, premium, if any, and interest on the 2026 Bonds paid or any redemption or other notices or that they will do so on a timely basis or will serve and act in the manner described in this Official

Attachment 2
F-3
Statement. The Authority and the Flood Control District are not responsible or liable for the failure of DTC or any Direct Participant or Indirect Participant to make any payments or give any notice to a Beneficial Owner with respect to the 2026 Bonds or any error or delay relating thereto.

None of the Authority, the Flood Control District, the Underwriter or the Trustee will have any responsibility or obligation to Direct Participants, to Indirect Participants or to any Beneficial Owner with respect to (i) the accuracy of any records maintained by DTC, any Direct Participant, or any Indirect Participant; (ii) the payment by DTC or any Direct Participant or Indirect Participant of any amount with respect to the principal of or premium, if any, or interest on the 2026 Bonds; (iii) any notice that is permitted or required to be given to Holders under the Indenture; (iv) the selection by DTC, any Direct Participant or any Indirect Participant of any person to receive payment in the event of a partial redemption of the 2026 Bonds; (v) any consent given or other action taken by DTC as Bondholder; or (vi) any other procedures or obligations of DTC, Direct Participants or Indirect Participants under the book-entry system.

Attachment 2
G-1
[APPENDIX G
SPECIMEN MUNICIPAL BOND INSURANCE POLICY]

Attachment 3
1 CITY OF EL PASO DE ROBLES

CONTINUING DISCLOSURE AGREEMENT
This Continuing Disclosure Agreement (the “Disclosure Agreement”), dated [_________], 2026, is executed and delivered by the City of El Paso de Robles (the “Obligated Person”) and the San Luis Obispo County Flood Control and Water Conservation District (the “Flood Control District”) in connection with the execution and delivery of $[PAR] principal amount of SLO County Financing Authority (County of San Luis Obispo, California) Nacimiento Water Project Revenue Refunding Bonds, 2026 Series A (the “2026 Bonds”). The 2026 Bonds will be issued and secured pursuant to the terms of an Indenture of Trust, dated as of September 1, 2007 (the “Original Indenture”), previously supplemented and amended, and as further supplemented and amended by the Third Supplemental Indenture of Trust dated as of [October 1], 2026 (the “Third Supplemental Indenture” and together with the Original Indenture, as previously supplemented and amended, the “Indenture”), each by and between the SLO County Financing Authority (the “Authority”) and U.S. Bank Trust Company, National Association, as successor trustee (the “Trustee”).

The Obligated Person covenants and agrees on behalf of the Authority as follows:

SECTION 1. Purpose of the Disclosure Agreement. This Disclosure Agreement is being executed and delivered by the Obligated Person for the benefit of the Beneficial Owners of the 2026 Bonds and in order to assist the Participating Underwriter in complying with S.E.C. Rule 15c2-12(b)(5).

SECTION 2. Definitions. In addition to the definitions set forth in the Indenture, which apply to any capitalized term used in this Disclosure Agreement unless otherwise defined in this Section, the following capitalized terms shall have the following meanings:
“Annual Disclosure Report” shall mean any Annual Disclosure Report provided by the Obligated Person pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. “Beneficial Owner” shall mean any person which (a) has the power, directly or indirectly, to vote or consent with respect to, or to dispose of ownership of any Bonds (including persons holding Bonds through nominees, depositories or other intermediaries), or (b) is treated as the owner of any Bonds for federal income tax purposes.
“Disclosure Representative” shall mean the Director of Finance of the Obligated Person or such other official as may be designated in writing to the Dissemination Agent (if other than the Obligated Person) from time to time.
“Dissemination Agent” shall mean the Flood Control District, acting in its capacity as Dissemination Agent hereunder, or any successor Dissemination Agent designated in writing by the Obligated Person and which has filed with the Obligated Person a written acceptance of such designation. “Filing Date” shall mean March 31 of the Fiscal Year of the Obligated Person (or the next succeeding business day if such day is not a business day), commencing March 31, 2027. “Fiscal Year” shall mean the period beginning on July 1 of each year and ending on the next succeeding June 30, or any other twelve-month period hereafter selected and designated as the official fiscal year period of the Obligated Person and certified to the Trustee in writing by an Authorized Representative of the Obligated Person.
“MSRB” shall mean the Municipal Securities Rulemaking Board or any other entity designated or authorized by the Securities and Exchange Commission to receive reports pursuant to the Rule. Until

Attachment 3
2 otherwise designated by the MSRB or the Securities and Exchange Commission, filings with the MSRB are to be made through the Electronic Municipal Market Access (EMMA) website of the MSRB, currently located at http://emma.msrb.org.
“Official Statement” means the Official Statement dated [_________], 2026 relating to the 2026 Bonds.
“Participating Underwriter” shall mean the original underwriter of the 2026 Bonds required to comply with the Rule in connection with offering of the 2026 Bonds. “Rule” shall mean Rule 15c2-12(b)(5) adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as the same may be amended from time to time.

SECTION 3. Provision of Annual Disclosure Reports.
(a) The Obligated Person shall provide, or shall cause the Dissemination Agent to provide, not later than the Filing Date, to the MSRB an Annual Disclosure Report which is consistent with the requirements of Section 4 of this Disclosure Agreement. The Annual Disclosure Report shall be submitted in electronic format, accompanied by such identifying information as is prescribed by the MSRB, and may be submitted as a single document or as separate documents comprising a package and may cross-reference other information as provided in the Disclosure Agreement. If the Fiscal Year of the Obligated Person changes, it shall give notice of such change to the Dissemination Agent not later than ten (10) business days after the occurrence of the event.
(b) Not later than fifteen (15) days prior to each Filing Date, commencing March 15, 2027, the Obligated Person shall provide the Annual Disclosure Report to the Dissemination Agent (if other than the Obligated Person). The Obligated Person shall provide, or cause the preparer of the Annual Disclosure Report to provide, a written certificate with each Annual Disclosure Report furnished to the Dissemination Agent to the effect that such Annual Disclosure Report constitutes the Annual Disclosure Report required to be furnished under the Disclosure Agreement. The Dissemination Agent may conclusively rely upon such certification and shall have no duty or obligation to review such Annual Disclosure Report. (c) The Flood Control District shall use its best efforts to assist the Obligated Person in preparing the Annual Disclosure Report for delivery to the Dissemination Agent no later than March 15 of each year.
(d) Not later than the Filing Date, the Dissemination Agent shall provide written notice confirming whether or not such Annual Disclosure Report has been furnished by the Obligated Person. (e) If the Obligated Person is unable to provide the Annual Disclosure Report to the Dissemination Agent by the Filing Date of each year commencing March 31, 2027, the Dissemination Agent shall send a notice to the MSRB in substantially the form attached as Exhibit A. (f) The Dissemination Agent shall:
(i) If not previously filed by the Obligated Person, send a notice to the MSRB if the Obligated Person is unable to provide the Annual Disclosure Report to the MSRB by the date required in subsection (a); and

Attachment 3
3 (ii) to the extent information is known to it, file a report with the Obligated Person certifying that the Annual Disclosure Report has been provided pursuant to this Disclosure Agreement, stating the date it was provided.

SECTION 4. Content of Annual Disclosure Reports. The Annual Disclosure Report shall contain or include by reference the following:
(a) The audited financial statements of the Obligated Person prepared in accordance with generally accepted accounting principles in effect from time to time. If any of such audited financial statements are not available by the time the Annual Disclosure Report is required to be filed pursuant to Section 3(a), the Annual Disclosure Report shall contain unaudited financial statements in a format similar to the financial statements contained in the Official Statement, and the audited financial statements shall be filed in the same manner as the Annual Disclosure Report when they become available. (b) Unless otherwise provided in the audited financial statements filed on or prior to the Filing Date, financial and operating data with respect to the Obligated Person for the preceding Fiscal Year, substantially similar to the financial and operating data in the Official Statement as follows:
(i) Principal and interest payment delinquencies;
(ii) Table A2-1 Water Connections;
(iii) Table A2-2 Water Deliveries;
(iv) Table A2-3 Water Sales Revenues;
(v) Secured assessed valuation†;
(vi) Table A2-6 Operating Results;
(vii) Information concerning any revisions to the adopted rates and charges which are generally imposed by the Obligated Person upon users within the service area of its Water Enterprise; and
(viii) For any customer whose total billings in the preceding Fiscal Year represent 10% or more of Gross Revenues of the Water Enterprise: (A) the total amount of Gross Revenues derived from such customer; and (B) the percent of Gross Revenues represented by such customer for such Fiscal Year.
(c) In addition to any of the information expressly required to be provided under Sections 4(a) and 4(b), the Obligated Person shall provide such other information, if any, as may be necessary to make the required statements, in light of the circumstances under which they were made, not misleading. (d) The presentation and format of the Annual Disclosure Reports may be modified from time to time as determined in the judgment of the Obligated Person to conform to changes in accounting or disclosure principles or practices and legal requirements followed by or applicable to the Obligated Person

† This data is provided for informational purposes only. The Obligated Person is a party to a Nacimiento Project Water Delivery Entitlement Contract (the “Delivery Contract”) with the Flood Control District that permits the Obligated Person to issue additional “Municipal Obligations” to fund all or a portion of the Delivery Contract Payments with the levy of ad valorem property taxes, special assessments or special taxes. As of the date of this Disclosure Agreement, the Obligated Person had not levied any ad valorem property taxes, special assessments or special taxes to fund any of its Delivery Contract Payments.

Attachment 3
4 to reflect changes in the business, structure, operations, legal form of the Obligated Person or any mergers, consolidations, acquisitions or dispositions made by or affecting the Obligated Person; provided that any such modifications shall comply with the requirements of the Rule.

Any or all of the items listed above may be included by specific reference to other documents, including official statements of debt issues of the Obligated Person or related public entities, which have been made available to the public on the MSRB website. The Obligated Person shall clearly identify each such other document so included by reference.

SECTION 5. Termination of Reporting Obligation. The obligations of the Obligated Person under this Disclosure Agreement shall terminate upon the legal defeasance, prior redemption or payment in full of all of the 2026 Bonds. If such termination occurs prior to the final maturity of the 2026 Bonds, the Obligated Person shall, promptly not later than ten (10) business days after the termination, give notice of such termination to the MSRB.

SECTION 6. Dissemination Agent. The Obligated Person may, from time to time, appoint or engage a Dissemination Agent to assist it in carrying out its obligations under this Disclosure Agreement, and may discharge any such Dissemination Agent, with or without appointing a successor Dissemination Agent. The Dissemination Agent may resign by providing thirty (30) days written notice to the Obligated Person.

The initial Dissemination Agent shall be the Flood Control District.

SECTION 7. Amendment; Waiver. Notwithstanding any other provision of this Disclosure Agreement, the Obligated Person may amend this Disclosure Agreement, and any provision of this Disclosure Agreement may be waived, provided that the following conditions are satisfied:
(a) If the amendment or waiver relates to the provisions of Sections 3(a), or 4, it may only be made in connection with a change in circumstances that arises from a change in legal requirements, change in law, or change in the identity, nature or status of an obligated person with respect to the 2026 Bonds, or the type of business conducted;
(b) The undertaking, as amended or taking into account such waiver, would, in the opinion of nationally recognized bond counsel, have complied with the requirements of the Rule at the time of the original execution and delivery of the 2026 Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; (c) The amendment or waiver either (i) is approved by the Holders of the 2026 Bonds in the same manner as provided in the Indenture for amendments to the Indenture with the consent of Holders, or (ii) does not, in the opinion of a nationally recognized bond counsel, materially impair the interests of the Holders or Beneficial Owners of the 2026 Bonds; and
(d) Any amendment that modifies or increases the duties or obligations of the Dissemination Agent shall be agreed to in writing by the Dissemination Agent.

In the event of any amendment or waiver of a provision of this Disclosure Agreement, the Obligated Person shall describe such amendment in the next Annual Disclosure Report, and shall include, as applicable, a narrative explanation of the reason for the amendment or waiver and its impact on the type (or, in the case of a change of accounting principles, on the presentation) of financial information or operating data being presented by the Obligated Person. In addition, if the amendment relates to the accounting principles to be followed in preparing financial statements, (i) notice of such change shall be

Attachment 3
5 given to the Dissemination Agent not later than ten (10) business days after the occurrence of the event, and (ii) the Annual Disclosure Report for the year in which the change is made shall present a comparison (in narrative form and also, if feasible, in quantitative form) between the financial statements as prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles.

SECTION 8. Additional Information. Nothing in this Disclosure Agreement shall be deemed to prevent the Obligated Person from disseminating any other information, using the means of dissemination set forth in this Disclosure Agreement or any other means of communication, or including any other information in any Annual Disclosure Report, in addition to that which is required by this Disclosure Agreement. If the Obligated Person chooses to include any information in any Annual Disclosure Report in addition to that which is specifically required by this Disclosure Agreement, the Obligated Person shall have no obligation under this Agreement to update such information or include it in any future Annual Disclosure Report.

SECTION 9. Default. This Disclosure Agreement shall be solely for the benefit of the holders and beneficial owners from time to time of the 2026 Bonds. In the event of a failure of the Obligated Person to comply with any provision of this Disclosure Agreement, the Trustee may (and, at the request of the Participating Underwriter or the Holders of at least twenty-five percent (25%) aggregate principal amount of Outstanding Bonds and upon receipt of indemnity satisfactory to the Trustee, shall), or any Holder or Beneficial Owner of the 2026 Bonds may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by order of a court of competent jurisdiction in San Luis Obispo County, California, to cause the Obligated Person to comply with its obligations under this Disclosure Agreement, provided that any holder or beneficial owner seeking to require the Obligated Person to comply with this Disclosure Agreement shall first provide at least thirty (30) days prior written notice to the Obligated Person of the failure of the Obligated Person, giving reasonable detail of such failure. Failure by the Obligated Person to comply with any provision of this Disclosure Agreement shall not be deemed an Event of Default under the Indenture, and the sole remedy under this Disclosure Agreement in the event of any failure of the Obligated Person to comply with the terms of this Disclosure Agreement shall be an action to compel performance. No person or entity shall be entitled to recover monetary damages under this Disclosure Agreement.

SECTION 10. Duties, Immunities and Liabilities of Dissemination Agent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Agreement, and the Obligated Person agrees to indemnify and save the Dissemination Agent, its officers, directors, employees and agents, harmless against any loss, expense and liabilities which it may incur arising out of or in the exercise or performance of its powers and duties hereunder, including the costs and expenses (including attorney’s fees) of defending against any claim of liability, but excluding liabilities due to the Dissemination Agent’s negligence or willful misconduct. The Dissemination Agent shall be paid compensation by the Obligated Person for its services provided hereunder in accordance with its schedule of fees as amended from time to time and all expenses, legal fees and advances made or incurred by the Dissemination Agent in the performance of its duties hereunder. The obligations of the Obligated Person under this Section 10 shall survive resignation or removal of the Dissemination Agent and payment of the 2026 Bonds.

SECTION 11. Notices. Any notices or communications to the Obligated Person or the Dissemination Agent may be given as follows:

Obligated Person:

City of El Paso de Robles
City Hall
1000 Spring Street

Attachment 3
6 Paso Robles, CA 93446
Attention: Director of Administrative Services
Phone: 805-237-3999
Dissemination Agent:

San Luis Obispo Flood Control and Water Conservation District County Government Center
1055 Monterey Street
San Luis Obispo, CA 93408
Attention: Auditor-Controller
Phone: 805-781-5043
Any person may, by written notice to the other persons listed above, designate a different address or telephone number(s) to which subsequent notices or communications should be sent.

SECTION 12. Beneficiaries. This Disclosure Agreement shall inure solely to the benefit of the Authority, the Flood Control District, the Trustee, the Dissemination Agent, the Participating Underwriter and Holders and Beneficial Owners from time to time of the 2026 Bonds, and shall create no rights in any other person or entity.

SECTION 13. Record Keeping. The Obligated Person shall maintain records of Annual Disclosure Reports, including the content of such disclosure, the name of the entities with which such disclosure was filed and the date of filing of such disclosure.

SECTION 14. Counterparts. This Disclosure Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument.

CITY OF EL PASO DE ROBLES
By:

Authorized Officer
Accepted:

SAN LUIS OBISPO COUNTY FLOOD CONTROL
AND WATER CONSERVATION DISTRICT, as
Dissemination Agent
By:

Chairman

Attachment 3
7 EXHIBIT A

NOTICE TO REPOSITORIES OF FAILURE TO FILE ANNUAL DISCLOSURE REPORT Name of Obligated Person: City of El Paso de Robles
Name of Bonds: SLO County Financing Authority (County of San Luis Obispo, California) Nacimiento Water Project Revenue Refunding Bonds, 2026 Series A Date of Delivery: [_________], 2026
NOTICE IS HEREBY GIVEN that the Obligated Person has not provided an Annual Disclosure Report with respect to the above-named Bonds as required by the Continuing Disclosure Agreement, dated as of [_________], 2026, with respect to the 2026 Bonds. [The Obligated Person anticipates that the Annual Disclosure Report will be filed by___________.]

SAN LUIS OBISPO COUNTY FLOOD CONTROL

AND WATER CONSERVATION DISTRICT
By:
[cc: Obligated Person]

Council Agenda Report
From: Angelica Fortin, Community Services Director
Subject: Receipt of Report Regarding Outcome of the Surplus Land Act Process for the Sale of Surplus Land at Pioneer Park and Direction for Future Consideration CEQA Determination: The City finds that this action is not a project under the California Environmental Quality Act pursuant to State Guidelines Section State CEQA Guidelines, §§ 15060, subd. (c)(2)-(3), 15378.

Date: August 18, 2026
Facts

1. The City currently owns real property located near 1910 Riverside Avenue in Paso Robles (a portion of APN 008-254-003), constituting approximately 71,874 square feet in area (“Property”). The Property is improved with a public park (i.e., Pioneer Park).

2. Pioneer Park currently includes restrooms, a small parking lot, and a skate park.

3. Effective January 1, 2020, AB 1486 amended the Surplus Land Act (“SLA”), Government Code Section 54220 et seq., which prescribes the process a local agency must follow before disposing of surplus land.

4. On November 18, 2025, the City Council adopted Resolution 25-130 declaring the Property nonexempt surplus land pursuant to Government Code Section 54221 and approving the Notice of Availability, in compliance with the requirements of the SLA.

5. Following adoption of the Resolution, City staff transmitted the Notice of Availability to all entities entitled to receive notice under the SLA. The City received three responses: The Housing Authority of San Luis Obispo (HASLO), The Pioneer Museum Foundation, and the Paso Robles Event Center (Fairgrounds). HASLO was the only respondent who proposed to build housing on the site. HASLO submitted a timely written notice of interest proposing the development of affordable housing and, pursuant to the SLA, the City and HASLO entered into good faith negotiations to determine a mutually satisfactory sale price and terms.

6. The City and HASLO engaged in good faith negotiations surpassing the 90-day period required by the SLA but were unable to reach agreement on a mutually satisfactory sale price or terms. Negotiations have since concluded, resulting in no sale of the Property.

7. The Property has since been appraised at a fair market value of $1,690,000.

8. Both the Pioneer Museum Foundation and the Paso Robles Event Center (Fairgrounds) have independently expressed interest in acquiring the Property for their respective operations.

9. The City is preparing to undertake a parks master planning process, which will include a comprehensive community engagement effort to evaluate the City’s park facilities and future recreational needs, including those served by the Property.

Options

1. Take no action;

2. Receive and file this report and direct staff to delay the consideration of a future sale of the Property until the City’s Parks Master Plan has been completed;

3. Direct staff to pursue disposition of the Property, including engaging with the Pioneer Museum Foundation and/or the Fairgrounds regarding their expressed interest in acquiring the Property;

4. Provide alternative direction to staff.

Analysis and Conclusions
In November 2025, the City Council found the Property to be non-exempt surplus land and directed staff to comply with the SLA. Consistent with that direction, staff transmitted the required Notice of Availability to all entities entitled to receive notice under the SLA. HASLO submitted a timely notice of interest, and the City engaged in good faith negotiations with HASLO for the statutorily required period of not less than 90 days. Despite these good faith efforts, the City and HASLO were unable to reach a mutually satisfactory sale price or terms. Accordingly, negotiations have concluded without a sale of the Property, and the City has provided a summary of the negations to the California Department of Housing and Community Development (HCD). HCD has, as of July 3, 2026, confirmed the City’s compliance with the SLA. The City may now dispose of the Property subject to the recordation of an affordable housing covenant which provides that if 10 or more units are built on the property no less than 15 percent will be affordable housing.

Two additional entities, the Pioneer Museum Foundation and the Fairgrounds, have separately expressed interest in acquiring the Property. While either expression of interest could form the basis of future disposition discussions, staff notes that the City is concurrently preparing to launch its Parks Master Planning process. That process will provide structured opportunities for community input regarding the City’s park system, green spaces, and future parks and recreational needs.

Given the Property’s continued use and history as a public park, and the fact that no sale resulted from the SLA process, staff recommends that the City retain the Property at this time and, at a minimum, through completion of the Parks Master Planning process. Retaining the Property will keep it within the City’s inventory and preserve it as a potential asset for future parks and recreational needs while the community’s priorities are evaluated through the master planning process. This approach will allow the City to consider the Property within the broader context of its overall park system and make a more informed decision regarding its long-term use or disposition.

Following completion of the Parks Master Planning process, staff can return to the City Council with recommendations regarding the Property based on the community’s identified needs and priorities. Any future decision to dispose of the Property would be brought back to the City Council for further consideration and compliance with any additional laws governing the disposition of park land.

Fiscal Impact
Receiving and filing this report and directing staff to retain the Property does not have a direct fiscal impact. However, it should be noted that retaining the Property carries certain near-term obligations. A portion of the original park parcel was previously sold to the Fairgrounds, and the City's current lease with the Fairgrounds for its continued use of the adjoining parcel expires in March 2027. If the City retains the Property, it will need to continue funding ongoing maintenance of the restroom facility and skatepark located on-site, both of which are existing park amenities that will remain the City's responsibility.

The Property has been valued at approximately $1.7 million. As such, retaining the Property forgoes potential sale proceeds at this time but preserves the City's option to pursue disposition, lease, or

continued park use following completion of the Parks Master Planning process. Should the City retain the Property for continued park use, separation of the water and electrical utilities currently shared with the adjacent property would be required.

CEQA
This report is informational and does not, by itself, authorize the sale, lease, or other disposition of the Property. Directing staff to retain the Property and await the outcome of the Parks Master Planning process does not have the potential for causing either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment and does not constitute a “project” under CEQA Guidelines Section 15378. Accordingly, this action is not subject to CEQA review pursuant to State CEQA Guidelines Sections 15060(c) and 15312. Should the City Council in the future direct staff to pursue disposition of the Property to a particular party for a particular use, that future action and any associated development proposal will be analyzed under CEQA at the appropriate time Recommendation (Option 2)
Receive and file this report and direct staff to delay the sale of real property pending the outcome of the upcoming Parks Master Plan.

Attachments

1. APN 008-254-003 - Property Description

2. APN 008-254-003 – Surplus Land Act Findings Letter

PROPERTY DESCRIPTION
Property Address: 1910 Riverside Ave, Paso Robles, CA 93446 APN: 008-254-003
Acres: 1.65
Zoning: Civic (C)
Attachment 1

SLA0002752
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street, Suite 400, Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
July 3, 2026
William Shepherd, BB&K Law
On behalf of City of Paso Robles
600 Nickerson Drive
Paso Robles, CA 93446
SENT VIA EMAIL TO: [email protected]
Dear William Shepherd:

RE: City of Paso Robles – APN 008-254-003 – Surplus Land Act Findings Letter Thank you for submitting your surplus land documentation, on behalf of the City of Paso Robles (City), for review by the California Department of Housing and Community Development (HCD). HCD received complete documentation on June13, 2026. This letter constitutes HCD’s written findings pursuant to Government Code section 54230.5 of the Surplus Land Act (SLA), for the surplus land identified as Assessor’s Parcel Number (APN) 008-254-003 (Property).

Analysis
According to your letter and included documents, Resolution 25-130 declaring the Property to be surplus was adopted on November 18, 2025 and Notices of Availability were sent on December 13, 2025. During the required 60-day period, one affordable housing entity initially expressed interest in the Property but sent a letter withdrawing interest during the 90-day good faith negotiation period. The City has provided a summary of negotiations and enclosed the appropriate draft affordability covenant, requiring 15 percent affordable housing, to be recorded against the Property.

Conclusion
If the submitted documentation and assertions by the City are complete and accurate, HCD finds that all the requirements under the SLA for the purposes of disposing of the Property have been met. Once a final disposition has taken place, please provide HCD with a copy of the respective recorded covenant pursuant to SLA Guidelines, Section 400(b)(1).

Attachment 2

William Shepherd, BB&K Law

SLA0002752
If you have any questions or need additional technical assistance, please contact Mathew Manweller, Senior Housing Specialist at [email protected] or submit a request via the Surplus Land Portal.

Sincerely,
Lisa Krause
Section Chief, Surplus Land Act
Housing Accountability Unit
Attachment 2