If the City shall be unable to satisfy the conditions to the Underwriter’s obligations contained in this Purchase Contract or if the Underwriter’s obligations shall be terminated for any reason Packet Pg. 342 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
14 permitted herein, all obligations of the Underwriter hereunder may be terminated by the Underwriter at, or at any time prior to, the Closing Date by written notice to the City and neither the Underwriter nor the City shall have any further obligations hereunder.
6. Reserved.
7. Expenses.
(a) The Underwriter shall be under no obligation to pay, and the City shall pay, any expenses incident to the performance of the City’s obligations hereunder including, but not limited to: (i) the cost of preparation, printing and distribution of the Financing Documents, the Preliminary Official Statement, the Official Statement and any supplements or amendments thereto, including a reasonable number of certified or conformed copies thereof; (ii) the cost of preparation and printing of the Bonds; (iii) the fees and disbursements of Bond Counsel and disclosure counsel; (iv) the fees and disbursements of any engineers, accountants and other experts, consultants, advisors, dissemination agents or other service providers retained by the City; (v) fees for bond ratings (which include fees of rating agencies and travel expenses of the City); and (vi) the Underwriter’s out-of-pocket expenses incurred with respect to the financing, including (a) air travel and hotel costs in connection with the pricing of the Bonds, any investor meetings, any rating agency trips and the Closing, (b) meals and transportation for the City, the Underwriter and other working group personnel during such trips, (c) expenses related to attending working group meetings, such as parking, meals and transportation, and (d) any other miscellaneous costs related to the Closing. (b) The Underwriter shall pay: (i) the cost of preparation and printing of this Purchase Contract and the Preliminary Blue Sky Survey; (ii) all advertising expenses and Blue Sky filing fees in connection with the public offering of the Bonds; (iii) fees, if any, payable to the California Debt and Investment Advisory Commission, the Municipal Securities Rulemaking Board and the fees associated with obtaining CUSIP numbers for the Bonds in connection with the execution and delivery of the Bonds; and (iv) all other expenses incurred by them in connection with the public offering of the Bonds not outlined in (a) above, including the fees and disbursements of Underwriter’s Counsel.
(c) The City acknowledgesthat it has had an opportunity, in consultation with such advisors as it may deem appropriate, if any, to evaluate and consider the fees and expenses being incurred as part of the issuance of the Bonds.
8. Notices. Any notice or other communication to be given (i) to the City under this Purchase Contract may be given by delivering the same in writing to the City, 777 Cypress Avenue, Redding, California 96001, and (ii) to the Underwriter under this Purchase Contract may be given by delivering the same in writing to the Underwriter: J.P. Morgan Securities LLC, 560 Mission Street, Floor Three, San Francisco, California 94105, Attention: Tyler Old.
9. Survival of Representations and Warranties. The City’s representations, warranties and agreements contained in this Purchase Contract or made in any certificate delivered hereunder shall remain operative and in full force and effect, regardless of: (i) any investigations or statements made by or on behalf of the Underwriter; and (ii) delivery of and payment for the Bonds pursuant to this Purchase Contract.
Packet Pg. 343 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
15 10. Effectiveness and Counterpart Signatures. This Purchase Contract shall become effective and binding upon the respective parties hereto upon the execution of the acceptance hereof by duly authorized officers of the City and shall be valid and enforceable as of the time of such acceptance. This Purchase Contract may be executed by the parties hereto in separate counterparts, each of which when so executed and delivered shall be an original, but all such counterparts shall together constitute but one and the same instrument.
11. Parties in Interest. This Purchase Contract is made solely for the benefit of the City and the Underwriter (including the successors or assigns of the Underwriter) and no other person shall acquire or have any right hereunder or by virtue hereof.
12. No Fiduciary. The City acknowledges and agrees that (i) the purchase and sale of the Bonds pursuant to this Purchase Contract is an arm’s-length commercial transaction between the City and the Underwriter, and that the Underwriter has financial and other interests that differ from those of the City, (ii) in connection therewith and with the discussions, undertakings and procedures leading up to the consummation of such transaction, the Underwriter is and has been acting solely as principal and is not acting as the agent or fiduciary of the City, (iii) the Underwriter has not assumed an advisory or fiduciary responsibility in favor of the City with respect to the offering contemplated hereby or the discussions, undertakings and procedures leading thereto (irrespective of whether the Underwriter has provided other services or are currently providing other services to the City on other matters) and the Underwriter has no obligation to the City with respect to the offering contemplated hereby except the obligations expressly set forth in this Purchase Contract and (iv) the City has consulted its own legal, financial and other advisors to the extent its has deemed appropriate.
13. Electronic Signatures. Each of the parties hereto agrees that the transaction consisting of this Purchase Contract may be conducted by electronic means. Each party agrees, and acknowledges that it is such party’s intent, that if such party signs this Purchase Contract using an electronic signature, it is signing, adopting, and accepting this Purchase Contract and that signing this Purchase Contract using an electronic signature is the legal equivalent of having placed its handwritten signature on this Purchase Contract on paper. Each party acknowledges that it is being provided with an electronic or paper copy of this Purchase Contract in a usable format.
14. Waiver of Jury Trial. TO THE EXTENT PERMITTED BY LAW, THE CITY AND
THE UNDERWRITER HEREBY KNOWINGLY, VOLUNTARILY, AND INTENTIONALLY
WAIVE ANY RIGHT TO TRIAL BY JURY THE CITY OR THE UNDERWRITER MAY HAVE
IN ANY ACTION OR PROCEEDING, IN LAW OR IN EQUITY, IN CONNECTION WITH THIS PURCHASE CONTRACT OR ANY TRANSACTIONS RELATED HERETO.
15. Headings. The headings of the sections of this Purchase Contract are inserted for convenience only and shall not be deemed to be a part hereof. [Signature page follows.]
Packet Pg. 344 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3 S-1
16. Governing Law. This Purchase Contract shall be construed in accordance with the laws of the State of California.
Very truly yours,
J.P. MORGAN SECURITIES LLC
By:
Executive Director
Accepted:
CITY OF REDDING
By:
City Manager
ACCEPTED at ______ p.m. California time this
[__th] day of [____], 2026
Packet Pg. 345 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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SCHEDULE I
City of Redding
Electric System Refunding Revenue Bonds, Series 2026
MATURITY SCHEDULE
Payment Dates
(June 1)[*]
Principal
Amount
Interest
Rate Yield Price
$ % %
$[_______] [___]% Term 2026A Bonds due June 1, 20[__][*]– Yield: [__]%; Price: [____] $[_______] [___]% Term 2026A Bonds due June 1, 20[__][*]– Yield: [__]%; Price: [____] C Priced to par call on June 1, 20[__]
* All maturities are 10% Test Maturities
Packet Pg. 346 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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Redemption of the Bonds
Optional Redemption. The Bonds maturing on or before June 1, 20[__] are not subject to optional redemption prior to maturity. The Bonds maturing on or after June 1, 20[__] are subject to redemption prior to their respective stated maturities at the direction of the City, from moneys deposited by the City from any source of available funds, as a whole or in part on any date (in such maturities as are designated by the City, or if the City fails to designate such maturities, in inverse order of maturity and by lot within a maturity) on or after June 1, 20[__], at a redemption price equal to the principal amount of the Bonds called for redemption together with accrued interest to the date fixed for redemption, without premium.
Mandatory Redemption. The term Bonds maturing on June 1, 20[__] (the “20[__] Term Bonds”) are subject to mandatory redemption prior to maturity, in part by lot, commencing on June 1, 20[__] and on each June 1 thereafter to and including June 1, 20[__], from scheduled Mandatory Sinking Fund Payments made by the City on such dates, at a redemption price equal to the principal amount of the 20[__] Term Bonds to be redeemed, together with accrued interest thereon to the date fixed for redemption, without premium, according to the following schedule (subject to modification in the event of optional redemption as described above):
20[__] Term Bonds
Redemption Date
(June 1)
Principal
Amount
$
20[__]†
_______________
† Final Maturity.
The term Bonds maturing on June 1, 20[__] (the “20[__] Term Bonds”) are subject to mandatory redemption prior to maturity, in part by lot, commencing on June 1, 20[__] and on each June 1 thereafter to and including June 1, 20[__], from scheduled Mandatory Sinking Fund Payments made by the City on such dates, at a redemption price equal to the principal amount of the 20[__] Term Bonds to be redeemed, together with accrued interest thereon to the date fixed for redemption, without premium, according to the following schedule (subject to modification in the event of optional redemption as described above):
20[__] Term Bonds
Redemption Date
(June 1)
Principal
Amount
$
20[__]†
_______________
† Final Maturity.
Packet Pg. 347 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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EXHIBIT A
FORM OF SUPPLEMENTAL OPINION OF BOND COUNSEL
__________, 2026
J.P. Morgan Securities LLC,
San Francisco, California
Re: $[PAR AMOUNT] City of Redding Electric System Refunding Revenue Bonds, Series 2026 Ladies and Gentlemen:
This letter is addressed to you, as Underwriter, pursuant to Section 5(i)(4) of the Purchase Contract, dated [____], 2026 (the “Purchase Contract”), between you and the City of Redding (the “City”), providing for the purchase of $[PAR AMOUNT] principal amount of City of Redding Electric System Refunding Revenue Bonds, Series 2026 (the “Bonds”). The Bonds are being issued pursuant to an indenture, dated as of [______] 1, 2026 (the “Indenture”), between the City and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the Indenture or, if not defined in the Indenture, in the Purchase Contract.
We have delivered our final legal opinion (the “Bond Opinion”) as bond counsel to the City concerning the validity of the Bonds and certain other matters, dated the date hereof and addressed to the City. You may rely on such opinion as though the same were addressed to you.
In connection with our role as bond counsel to the City, we have reviewed the Purchase Contract, the Indenture, the Tax Certificate, dated the date hereof (the “Tax Certificate”), certain provisions of the posted preliminary official statement of the City, dated [______], 2026, with respect to the Bonds (the “Preliminary Official Statement”), certain provisions of the posted official statement of the City, dated [____], 2026, with respect to the Bonds (the “Official Statement”), opinions of counsel to the City and the Trustee, certificates of the City, the Trustee and others, and such other documents, opinions and matters to the extent we deemed necessary to render the opinions set forth herein.
The opinions expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such opinions may be affected by actions taken or omitted or events occurring after the original delivery of the Bonds on the date hereof. We have not undertaken to determine, or to inform any person, whether any such actions are taken or omitted or events do occur or any other matters come to our attention after the original delivery of the Bonds on the date hereof. We have assumed the genuineness of all documents and signatures provided to us and the due and legal execution and delivery of each such document by each party thereto other than the City and that each such document constitutes a valid and binding agreement of such party. We have assumed, without undertaking to verify, the accuracy of the factual matters represented, warranted or certified in the documents, and of the legal conclusions contained in the opinions, referred to in the third paragraph hereof. We have further assumed compliance with all covenants and agreements contained in such documents. In addition, we call attention to the fact that the rights and obligations under the Bonds, the Indenture, the Tax Certificate and the Purchase Contract Packet Pg. 348 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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and their enforceability may be subject to bankruptcy, insolvency, receivership, reorganization, arrangement, fraudulent conveyance, moratorium and other laws relating to or affecting creditors’ rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against governmental entities such as the City in the State of California. We express no opinion with respect to any indemnification, contribution, liquidated damages, penalty (including any remedy deemed to constitute a penalty), right of set-off, arbitration, judicial reference, choice of law, choice of forum, choice of venue, non-exclusivity of remedies, waiver or severability provisions contained in the foregoing documents, nor do we express any opinions with respect to the state or quality of title to or interest in any real or personal property described in or as subject to the lien of the Indenture or the accuracy or sufficiency of the description contained therein of, or the remedies available to enforce liens on, any such property. Finally, we undertake no responsibility for the accuracy, except as expressly set forth in numbered paragraph 3 below, completeness or fairness of the Preliminary Official Statement, the Official Statement or other offering material relating to the Bonds and express no view with respect thereto.
Based on and subject to the foregoing, and in reliance thereon, as of the date hereof, we are of the following opinions:
1. The Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Indenture is exempt from qualification pursuant to the Trust Indenture Act of 1939, as amended.
2. The Purchase Contract has been duly executed and delivered by, and constitutes a valid and binding agreement of, the City.
3. The statements contained in the Preliminary Official Statement and in the Official Statement under the captions “THE 2026A BONDS,” “SECURITY AND SOURCES OF PAYMENT FOR THE 2026A BONDS,” and “TAX MATTERS,” and in “APPENDIX [D] – SUMMARY OF CERTAIN PROVISIONS OF THE PRINCIPAL LEGAL DOCUMENTS,” and “APPENDIX [F] – PROPOSED FORM OF OPINION OF BOND COUNSEL,” excluding any material that may be treated as included under such captions by cross reference or reference to other documents or sources, insofar as such statements expressly summarize certain provisions of the Indenture, and certain matters addressed in the Bond Opinion, are accurate in all material respects.
This letter is furnished by us as bond counsel to the City. No attorney-client relationship has existed or exists between our firm and you in connection with the Bonds or by virtue of this letter. We disclaim any obligation to update this letter. This letter is delivered to you as underwriter of the Bonds, is solely for your benefit as such underwriter in connection with the original delivery of the Bonds on the date hereof, and is not to be used, circulated, quoted or otherwise referred to or relied upon for any other purpose or by any other person. This letter is not intended to, and may not, be relied upon by owners of the Bonds or by any other party to whom it is not specifically addressed.
Very truly yours,
Packet Pg. 349 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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EXHIBIT B
FORM OF OPINION OF DISCLOSURE COUNSEL
[Closing Date], 2026
City of Redding
Redding, California
J.P. Morgan Securities LLC,
as Underwriter
San Francisco, California
Re: $[PAR AMOUNT] City of Redding Electric System Refunding Revenue Bonds, Series 2026
Ladies and Gentlemen:
We have acted as Disclosure Counsel to the City of Redding (the “City”) in connection with the offering and sale of the City of Redding Electric System Refunding Revenue Bonds, Series 2026 in the aggregate principal amount of $[PAR AMOUNT] (the “Bonds”). The Bonds are being issued pursuant to Articles 10 and 11, Chapter 3, Part 1, Division 2, Title 5 of the Government Code of the State of California, and a Indenture, dated as of [______] 1, 2026, by and between the City and U.S. Bank Trust Company, National Association, as trustee. The Bonds were sold by the City to J.P. Morgan Securities LLC, as underwriter (the “Underwriter”), and are being delivered on the date hereof, pursuant to a Purchase Contract, dated [____], 2026 (the “Purchase Contract”), between the City and the Underwriter.
We have reviewed the Preliminary Official Statement dated [______], 2026 with respect to the Bonds (the “Preliminary Official Statement”) and the Official Statement dated [____], 2026 with respect to the Bonds (the “Official Statement”), the letters, certificates and opinions delivered pursuant to the Purchase Contract and otherwise in connection with the Bonds on the date hereof, and such other records, opinions and documents, and we have made such investigations of law and fact, as we have deemed appropriate as a basis for the conclusions hereinafter expressed. Unless otherwise indicated, capitalized terms used herein have the respective meanings given to such terms in the Official Statement.
We have assumed, but not independently verified, that the signatures on all documents, letters, opinions and certificates which we have examined are genuine, and that all documents submitted to us are authentic and were duly and properly executed by the parties thereto. We have also assumed, without undertaking to verify, the accuracy of the factual matters represented, warranted or certified in the documents, and of the legal conclusions contained in the opinions, referred to in the second paragraph hereof.
The conclusions that are expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such conclusions may be affected by actions taken or omitted or events occurring after the date hereof. We have not undertaken to determine, or to inform you or any other person, whether any such actions are taken or omitted or whether such events do occur or any other matters come to our attention after the date hereof.
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In our capacity as Disclosure Counsel, we have rendered certain legal advice and assistance to the City in connection with the preparation of the Preliminary Official Statement and the Official Statement.
Rendering such legal advice and assistance involved, among other things, discussions and inquiries concerning various legal matters, review of certain records, documents and proceedings, and participation in conferences with, among others, representatives of the City, the City Attorney, Orrick, Herrington & Sutcliffe LLP, as Bond Counsel, PFM Financial Advisors LLC, as municipal advisor to the City, the Underwriter, Norton Rose Fulbright US LLP, as counsel to the Underwriter, and others, during which conferences the contents of the Preliminary Official Statement and the Official Statement and related matters were discussed. On the basis of the information made available to us in the course of the foregoing (but without having undertaken to determine or verify independently, or assuming any responsibility for, the accuracy, completeness or fairness of any of the statements contained in the Preliminary Official Statement or the Official Statement), as of the date hereof no facts have come to the attention of the personnel in our firm directly involved in rendering legal advice and assistance in connection with the preparation of the Preliminary Official Statement and the Official Statement that causes us to believe that (a) the Preliminary Official Statement as of its date and as of the date of the Purchase Contract contained any untrue statement of a material fact or omitted to state a material fact necessary in order to make the statements made therein, in the light of the circumstances under which they were made, not misleading (excluding therefrom any financial, statistical or economic data or forecasts, numbers, charts, tables, graphs, estimates, projections, assumptions or expressions of opinion contained in the Preliminary Official Statement, information in the Appendices to the Preliminary Official Statement, information on the inside front cover of the Preliminary Official Statement, CUSIP numbers, information under the caption “UNDERWRITING,” any information that is incorporated by reference into the Preliminary Official Statement, any information about book-entry or The Depository Trust Company (“DTC”) included therein, or information permitted to be omitted therefrom pursuant to Rule 15c2-12 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 15c2-12”), as to all of which no opinion or view is expressed), or (b) the Official Statement as of its date or as of the date hereof contained or contains any untrue statement of a material fact or omitted to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading (excluding therefrom any financial, statistical or economic data or forecasts, numbers, charts, tables, graphs, estimates, projections, assumptions or expressions of opinion contained in the Official Statement, information in the Appendices to the Official Statement, information on the inside front cover of the Official Statement, CUSIP numbers, information under the caption “UNDERWRITING,” any information that is incorporated by reference into the Official Statement and any information about book-entry or DTC included therein, as to all of which we express no view). We advise you that, other than reviewing the various certificates and opinions required by the Purchase Contract regarding the Preliminary Official Statement and the Official Statement, we have not taken any steps since the date of the Official Statement to verify the accuracy of the statements contained in the Preliminary Official Statement or the Official Statement as of the date hereof.
In connection with the Bonds, we were not requested to, and did not, undertake an independent review on the Electronic Municipal Market Access website of the City’s past compliance with any continuing disclosure undertaking of the City pursuant to Rule 15c2-12. Our services as Disclosure Counsel to the City did not involve the rendering of financial or other non-legal advice to the City or any other party to the transaction.
By acceptance of this letter, you acknowledge that the preceding paragraph is neither a legal opinion nor a guarantee regarding the Official Statement; rather it is a statement of negative assurance regarding factual information that did not come to the attention of attorneys in our firm working on this matter during the limited activities that we performed as Disclosure Counsel concerning the Official Statement. Further, in accepting this letter the City recognizes and acknowledges that (i) the scope of those activities performed by us were inherently limited and do not encompass all activities that the City may be responsible to undertake in preparing the Official Statement, (ii) those activities performed by us relied substantially on representations, warranties, certifications and opinions made by representatives of the City and others, and Packet Pg. 351 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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are otherwise subject to the matters set forth in this letter, and (iii) while such statements of negative assurance are customarily given to underwriters of municipal bonds to assist them in discharging their responsibilities under federal securities laws, the responsibilities of the City under those laws may differ from those of underwriters in material respects, and the preceding paragraph may not serve the same purpose or provide the same utility to them as it would to the underwriters.
The conclusions expressed in this letter are limited to matters governed by the federal securities law of the United States, and we assume no responsibility with respect to the applicability or effect of the laws of any other jurisdiction.
We are furnishing this letter as Disclosure Counsel to the City, and not as counsel to the Underwriter. No attorney-client relationship has existed or exists between our firm and the Underwriter in connection with the Bonds or by virtue of this letter. We note that the Underwriter are represented by separate counsel retained by them in connection with the sale of the Bonds. This letter is delivered in connection with such transaction, and may not be used, circulated, quoted or otherwise referred to or relied upon by, any other person, firm, corporation or other entity, or filed with any governmental or other administrative agency for any purpose, without our prior written consent. Our engagement with respect to this matter terminates upon the delivery of this letter to you on the date hereof, and we have no obligation to update this letter.
Very truly yours,
Packet Pg. 352 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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EXHIBIT C
FORM OF OPINION OF CITY ATTORNEY
__________, 2026
J.P. Morgan Securities LLC
Los Angeles, California
$[PAR AMOUNT]
City of Redding
Electric System Refunding Revenue Bonds, Series 2026
Ladies and Gentlemen:
I have served as counsel to the City of Redding (the “City”) in connection with the issuance of $[PAR AMOUNT] principal amount of City of Redding Electric System Refunding Revenue Bonds, Series 2026 (the “Bonds”). The Bonds are being issued pursuant to a Indenture, dated as of [______] 1, 2026 (the “Indenture”), by and between the City and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). I have examined the following documents: (i) the Indenture, (ii) the Continuing Disclosure Agreement dated [CLOSING DATE], 2026 (the “Continuing Disclosure Agreement”), by and between the City and the Trustee, as Dissemination Agent, (iii) the Purchase Contract, dated [____], 2026 (the “Purchase Contract”), by and between J.P. Morgan Securities LLC and the City, (iv) the Preliminary Official Statement, dated [______], 2026 (the “Preliminary Official Statement”) relating to the Bonds, and (v) the Official Statement, dated [____], 2026 (the “Official Statement”) relating to the Bonds, and have made such other investigations of law and fact as I have deemed necessary to render the following opinion. Terms used herein and not defined shall have the meanings given such terms in the Purchase Contract.
It is my opinion that:
(1) The City is a general law city and municipal corporation, duly created, organized and existing under and pursuant to the Constitution and laws of the State of California and duly qualified to furnish electric service within said City.
(2) The City has the authority and right to execute, deliver and perform the Indenture, the Continuing Disclosure Agreement and the Purchase Contract (the “Financing Documents”), and the City has complied with the provisions of applicable law in all matters relating to the transactions contemplated by the Financing Documents.
(3) The resolution of the City (the “Resolution”) approving and authorizing the execution and delivery of the Financing Documents and approving the delivery and distribution of the Preliminary Official Statement and the execution, delivery and distribution of the Official Statement was duly adopted at a regular meeting of the City Council, which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout.
The Resolution is in full force and effect and has not been amended, modified, supplemented or rescinded.
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(4) The Financing Documents have been duly authorized, executed and delivered by the City and, assuming due authorization, execution and delivery by and enforceability against the other parties thereto, the Financing Documents constitute the legal, valid and binding agreements of the City, enforceable in accordance with their respective terms, subject in each case to the laws relating to bankruptcy, insolvency, reorganization, arrangement, fraudulent conveyance, moratorium or other laws relating to or affecting the enforcement of creditors’ rights generally and the application of equitable principles if equitable remedies are sought, including without limitation concepts of materiality, reasonableness, good faith and fair dealing, to the possible unavailability of specific performance or injunctive relief, and to the limitations on legal remedies against public agencies in the State of California.
(5) No approval, consent or authorization of any governmental or public agency, authority or person is required for the execution, delivery and performance by the City of the Financing Documents, or the performance by the City of its obligations thereunder which has not been obtained.
Under the laws of the State of California, the City has the authority to determine, fix, impose and collect rates and charges for electric service and is not presently subject to the regulatory jurisdiction of any state, regional or local governmental regulatory authority. (6) The execution and delivery of the Financing Documents by the City and compliance with the provisions thereof will not conflict with or constitute a breach of or default under any instrument relating to the organization, existence or operation of the City, or commitment, agreement or other instrument to which the City is a party or by which it or its property is bound or affected, or any ruling, regulation, ordinance, judgment, order or decree to which the City or any of its officers in their respective capacities as such are subject or any provision of the laws of the State of California relating to the City and its affairs.
(7) Based upon my participation in the preparation of the Preliminary Official Statement and the Official Statement and without having undertaken to determine independently the accuracy, completeness or fairness of the statements contained in the Preliminary Official Statement or the Official Statement, nothing has come to my attention that would lead me to believe that (a) the Preliminary Official Statement as of its date and as of the date of the Purchase Contract contained any untrue statement of a material fact or omitted to state a material fact necessary in order to make the statements made therein, in the light of the circumstances under which they were made, not misleading (excluding therefrom any financial, statistical or economic data or forecasts, numbers, charts, tables, graphs, estimates, projections, assumptions or expressions of opinion contained in the Preliminary Official Statement, information in the Appendices to the Preliminary Official Statement, information on the inside front cover of the Preliminary Official Statement, CUSIP numbers, information under the caption “UNDERWRITING,” any information that is incorporated by reference into the Preliminary Official Statement, any information about book-entry or The Depository Trust Company (“DTC”) included therein, or information permitted to be omitted therefrom pursuant to Rule 15c2-12 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 15c2-12”), as to all of which no opinion or view is expressed), or (b) the Official Statement (excluding therefrom the financial statements, the statistical data and the information concerning The Depository Trust Company, the book-entry system, the information under the caption “UNDERWRITING” and in Appendix [A] and Appendices [C through G] thereto, as to which no opinion is expressed), as of its date and the date hereof, contained or contains any untrue statement of a material fact or omitted or omits to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading.
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(8) There is no action, suit, proceeding, inquiry or investigation at law or in equity, or before any court, public board or body, pending or, to the best of my knowledge, threatened against or affecting the City or any entity affiliated with the City or any of its officers in their respective capacities as such (nor to the best of my knowledge, is there any basis therefor) that questions the powers of the City referred to in paragraph 2 above or in connection with the transactions contemplated by the Preliminary Official Statement and the Official Statement, or the validity of the proceedings taken by the City in connection with the authorization, execution or delivery of the Financing Documents, or wherein any unfavorable decision, ruling or finding would adversely affect the transactions contemplated by the Financing Documents, the Preliminary Official Statement or the Official Statement, or that, in any way, would adversely affect the validity or enforceability of the Financing Documents or, in any material respect, the ability of the City to perform its obligations under the Financing Documents.
Very truly yours,
Packet Pg. 355 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
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EXHIBIT D
[FORM OF UNDERWRITER ISSUE PRICE CERTIFICATE]
$[PAR AMOUNT]
City of Redding
Electric System Refunding Revenue Bonds, Series 2026
ISSUE PRICE CERTIFICATE
The undersigned, J.P. Morgan Securities LLC (the “Underwriter”), hereby certifies as set forth below with respect to the sale and issuance of the above-captioned obligations (the “Bonds”) of the City of Redding (the “Issuer”).
1. Sale of the General Rule Maturities. As of the date of this certificate, for each Maturity of the General Rule Maturities, the first price at which at least 10% of such Maturity was sold to the Public is the respective price listed in Schedule A.
2. Initial Offering Price of the Hold-the-Offering-Price Maturity. (a) The Underwriter has offered the Hold-the-Offering-Price Maturity to the Public for purchase at its initial offering price listed in Schedule A (the “Initial Offering Prices”) on or before the Sale Date. A copy of the pricing wire or equivalent communication for the Bonds is attached to this certificate as Schedule B.
(b) As set forth in the Purchase Contract dated [____], 2026, between the Underwriter and the Issuer, the Underwriter agreed in writing on or prior to the Sale Date that, (i) for the Hold-theOffering-Price Maturity, they would neither offer nor sell any of the Bonds of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the “hold-the-offering-price rule”), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any third-party distribution agreement shall contain the agreement of each broker-dealer who is a party to the thirdparty distribution agreement, to comply with the hold-the-offering-price rule. Pursuant to such agreement, the Underwriter has not offered or sold any of the Allocated Portion of the Hold-theOffering-Price Maturity at a price that is higher than its Initial Offering Price for that Maturity of the Bonds during the Holding Period.
3. Defined Terms.
(a) Allocated Portion means that portion of the Hold-the-Offering Price Maturity that was retained by or allocated to the Underwriter, as identified in Schedule A. (b) General Rule Maturities means those Maturities of the Bonds listed in Schedule A hereto as the “General Rule Maturities.”
(c) Hold-the-Offering-Price Maturity means that Maturity of the Bonds listed in Schedule A hereto as the “Hold-the-Offering-Price Maturity.” (d) Holding Period means, with respect to a Hold-the-Offering-Price Maturity, the period starting on the Sale Date and ending on the earlier of (i) the close of the fifth business day after the Packet Pg. 356 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
D-2
Sale Date, or (ii) the date on which the Underwriter sold at least 10% of such Hold-the-Offering-Price Maturity to the Public at prices that are no higher than the Initial Offering Price for such Hold-theOffering-Price Maturity. (e) Maturity means Bonds with the same credit and payment terms. Bonds with different maturity dates, or Bonds with the same maturity date but different stated interest rates, are treated as separate maturities.
(f) Public means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter.
The term “related party” for purposes of this certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. (g) Sale Date means the first day on which there is a binding contract in writing for the sale of a Maturity of the Bonds. The Sale Date of the Bonds is [____], 2026. (h) Underwriter means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Bonds to the Public (including a member of a selling group or a party to a third-party distribution agreement participating in the initial sale of the Bonds to the Public).
The representations set forth in this certificate are limited to factual matters only. Nothing in this certificate represents the undersigned’s interpretation of any laws, including specifically Sections 103 and 148 of the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the Tax Certificate with respect to the Bonds and with respect to compliance with the federal income tax rules affecting the Bonds, and by Orrick, Herrington & Sutcliffe LLP in connection with rendering its opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other federal income tax advice that it may give to the Issuer from time to time relating to the Bonds.
IN WITNESS WHEREOF, the undersigned has executed this certificate on this [__th] day of [____], 2026.
J.P. MORGAN SECURITIES LLC
By:
Name:
Title:
Packet Pg. 357 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
D-3
SCHEDULE A
SALE PRICES OF THE GENERAL RULE MATURITIES AND
INITIAL OFFERING PRICES OF THE HOLD-THE-OFFERING-PRICE MATURITY (Attached)
Packet Pg. 358 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) 301212959.3
D-4
SCHEDULE B
PRICING WIRE OR EQUIVALENT COMMUNICATION
(Attached)
Packet Pg. 359 Attachment: Purchase Contract (9.5(b)--Consider Authorization of Bond Refunding 2015A) Stradling Draft of 5/19/26
1 4916-3645-5085v2/200986-0003
CONTINUING DISCLOSURE AGREEMENT
This Continuing Disclosure Agreement (the “Disclosure Agreement”), dated ____, 2026, is executed and delivered by the City of Redding, California (the “City”) and U.S. Bank Trust Company, National Association in its capacity as dissemination agent (the “Dissemination Agent”) in connection with the issuance of $[Par] aggregate principal amount of City of Redding Electric System Refunding Revenue Bonds, Series 2026 (the “Bonds”). The Bonds are being issued pursuant to an Indenture, dated as of July 1, 2026 (the “Indenture”), by and between the City and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). In connection therewith the City and the Trustee covenant and agree as follows:
Section 1. Purpose of this Disclosure Agreement. This Disclosure Agreement is being executed and delivered by the City and the Dissemination Agent for the benefit of the Holders and Beneficial Owners of the Bonds and in order to assist the Participating Underwriter (as defined herein) in complying with Securities and Exchange Commission Rule 15c2-12(b)(5).
Section 2. Definitions. In addition to the definitions set forth above and in the Indenture, which apply to any capitalized term used in this Disclosure Agreement unless otherwise defined in this Section 2, the following capitalized terms shall have the following meanings:
“Annual Report” shall mean any Annual Report provided by the City pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. “Beneficial Owner” shall mean any person who (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 City Manager or the Director of Finance of the City, or such other officer or employee as the City shall designate in writing to the Trustee from time to time.
“Dissemination Agent” shall mean initially, U.S. Bank Trust Company, National Association, acting in its capacity as Dissemination Agent hereunder, or any successor Dissemination Agent designated in writing by the City and which has filed with the Trustee a written acceptance of such designation.
“Holder” shall mean either the registered owners of the Bonds or, if the Bonds are registered in the name of The Depository Trust Company or another recognized depository, any applicable participant in such depository system.
“Listed Event” shall mean any of the events listed in Section 5(a) of this Disclosure Agreement. “MSRB” shall mean the Municipal Securities Rulemaking Board established pursuant to Section 15B(b)(1) of the Securities Exchange Act of 1934 or any other entity designated or authorized by the Securities and Exchange Commission to receive reports pursuant to the Rule. Until 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.
Packet Pg. 360 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 2 4916-3645-5085v2/200986-0003
“Official Statement” shall mean the Official Statement dated _______, 2026, relating to the Bonds.
“Participating Underwriter” shall mean any of the original underwriter of the Bonds listed on the cover page of the Official Statement required to comply with the Rule in connection with offering of the Bonds.
“Rule” shall mean Rule 15c2-12(b)(5) adopted by the SEC under the Securities Exchange Act of 1934, as the same may be amended from time to time.
“SEC” shall mean the United States Securities and Exchange Commission.
Section 3. Provision of Annual Reports.
(a) The City shall, or shall cause the Dissemination Agent to, not later than 270 days after the end of the City’s Fiscal Year (which Fiscal Year presently ends on June 30), commencing with the report for the 2025-26 Fiscal Year, provide to the MSRB an Annual Report which is consistent with the requirements of Section 4 of this Disclosure Agreement. The Annual Report must be submitted in electronic format, accompanied by such identifying information as prescribed by the MSRB. The Annual Report may be submitted as a single document or as separate documents comprising a package, and may cross-reference other information as provided in Section 4 of this Disclosure Agreement; provided that if the audited financial statements of the City’s Electric Utility Fund are not available by the date required above for the filing of the Annual Report, the City shall submit the audited financial statements as soon thereafter as available. If the City’s Fiscal Year changes, it shall give notice of such change in the same manner as for a Listed Event under Section 5. (b) If the City is unable to provide to the MSRB an Annual Report by the date required in subsection (a), the City shall, or shall cause the Dissemination Agent to, send to the MSRB a notice in substantially the form attached hereto as Exhibit A. (c) The Dissemination Agent shall:
(i) determine the electronic filing address of, and then-current procedures for submitting Annual Reports to, the MSRB each year prior to the date for providing the Annual Report; and
(ii) file a report with the City and (if the Dissemination Agent is not the Trustee, the Trustee) certifying that the Annual Report has been provided to the MSRB pursuant to this Disclosure Agreement, and stating the date it was provided.
Section 4. Content of Annual Reports. The City’s Annual Report shall contain or include by reference the following categories or similar categories of information updated to incorporate information for the most recent Fiscal Year (the tables referred to below are those appearing in the Official Statement relating to the Bonds):
(i) The audited financial statements of the City’s Electric Utility Fund (which may be included as a component of the City’s city-wide audited financial statements) for the most recently completed Fiscal Year, prepared in accordance with generally accepted accounting principles for governmental enterprises as prescribed from time to time by any regulatory body with jurisdiction over the City and by the Packet Pg. 361 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 3 4916-3645-5085v2/200986-0003
Governmental Accounting Standards Board. If the City’s Electric Utility Enterprise Fund audited financial statements are not available by the time the Annual Report is required to be filed pursuant to Section 3(a), the Annual Report shall contain unaudited financial statements in a format similar to the audited financial statements, and the audited financial statements shall be filed in the same manner as the Annual Report when they become available.
(ii) Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT POWER SUPPLY RESOURCES” as it appears in the Official Statement;
(iii) Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT CUSTOMERS, SALES, REVENUES AND DEMAND” as it appears in the Official Statement; (iv) Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT SUMMARY OF OPERATING RESULTS” as it appears in the Official Statement; and (v) Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT OUTSTANDING DEBT OF JOINT POWERS AGENCIES” as it appears in the Official Statement.
Financial and operating information relating to the City referenced in items (ii)-(v) above may be updated from time to time, and such updates may involve displaying data in a different format or eliminating data that is no longer material.
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 City or related public entities, which have been submitted to the MSRB or the SEC. If any document included by reference is a final official statement, it must be available from the MSRB. The City shall clearly identify each such other document so included by reference.
Section 5. Reporting of Listed Events.
(a) Pursuant to the provisions of this Section 5, upon the occurrence of any of the following events (in each case to the extent applicable) with respect to the Bonds, the City shall give, or cause to be given by so notifying the Dissemination Agent in writing and instructing the Dissemination Agent to give, notice of the occurrence of such event, in each case, pursuant to Section 5(c) hereof:
1. principal or interest payment delinquencies;
2. non-payment related defaults, if material;
3. unscheduled draws on the debt service reserves reflecting financial difficulties;
4. unscheduled draws on the credit enhancements reflecting financial difficulties;
5. substitution of credit or liquidity providers, or their failure to perform; Packet Pg. 362 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4 4916-3645-5085v2/200986-0003
6. adverse tax opinions or the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax status of the Bonds, or other material events affecting the tax status of the Bonds;
7. modifications to the rights of the Bondholders, if material;
8. optional, contingent or unscheduled calls, if material, and tender offers;
9. defeasances;
10. release, substitution or sale of property securing repayment of the Bonds, if material;
11. rating changes;
12. bankruptcy, insolvency, receivership or similar proceedings of the City, which shall occur as described below;
13. the consummation of a merger, consolidation, or acquisition involving the City or the sale of all or substantially all of the assets of the City’s Electric System other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material;
14. appointment of a successor or additional trustee or the change of name of a trustee, if material;
15. incurrence of a Financial Obligation of the City with respect to the Electric System, if material, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of the City with respect to the Electric System, any of which affects Holders of the Bonds, if material; or
16. default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a Financial Obligation of the City with respect to the Electric System, any of which reflect financial difficulties.
For these purposes, (i) any event described in item 12 of this Section 5(a) is considered to occur when any of the following occur: the appointment of a receiver, fiscal agent, or similar officer for the City in a proceeding under the United States Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the City or its Electric System, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement, or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the City or its Electric System; and (ii) the City intends to comply with the provisions hereof for the Listed Events described in subparagraphs (15) and (16) of this Section 5(a), and Packet Pg. 363 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 5 4916-3645-5085v2/200986-0003
the definition of the “Financial Obligation” in Section 2, with reference to the Rule, any other applicable federal securities laws and guidance provided by the SEC in its Release No. 34-83885 dated August 20, 2018 (the “2018 Release”), any further amendments or written guidance provided by the SEC or its staff with respect to the amendments to the Rule effected by the 2018 Release. (b) Upon receipt of notice from the City and instruction by the City to report the occurrence of any Listed Event, the Dissemination Agent shall provide notice thereof to the MSRB in accordance with Section 5(c) hereof. In the event the Dissemination Agent shall obtain actual knowledge of the occurrence of any of the Listed Events, the Dissemination Agent shall, immediately after obtaining such knowledge, contact the Disclosure Representative, inform such person of the event, and request that the City promptly notify the Dissemination Agent in writing whether or not to report the event pursuant to Section 5(c). For purposes of this Disclosure Agreement, “actual knowledge” of the occurrence of such Listed Event shall mean actual knowledge by the Dissemination Agent, if other than the Trustee, and if the Dissemination Agent is the Trustee, then by the officer at the corporate trust office of the Trustee with regular responsibility for the administration of matters related to the Indenture. The Dissemination Agent shall have no responsibility to determine the materiality, if applicable, of any of the Listed Events. (c) The City, or the Dissemination Agent, if the Dissemination Agent has been instructed by the City to report the occurrence of a Listed Event pursuant to Section 5(b), shall file a notice of the occurrence of any of the events listed in Section 5(a) hereof with the MSRB in a timely manner not more than ten (10) business days after the occurrence of the event.
Section 6. Termination of Reporting Obligation. The City’s obligations under this Disclosure Agreement shall terminate with respect to all Bonds upon the maturity, legal defeasance, prior redemption or payment in full of all of the Bonds and with respect to any Bonds upon the maturity, defeasance, prior redemption or payment in full of such Bonds.
Section 7. Dissemination Agent. The City 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. If at any time there is not any other designated Dissemination Agent, the Trustee, upon notice from the City, shall be the Dissemination Agent. The initial Dissemination Agent shall be the Trustee.
The Dissemination Agent shall not be responsible in any manner for the content of any notice or report prepared by the City pursuant to this Disclosure Agreement. The Dissemination Agent shall receive compensation for the services provided pursuant to this Disclosure Agreement.
Section 8. Amendment; Waiver. Notwithstanding any other provision of this Disclosure Agreement, the City and the Dissemination Agent may amend this Disclosure Agreement, (and, to the extent that any such amendment does not materially change or increase its obligations hereunder, the Dissemination Agent shall agree to any amendment so requested by the City), 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 Section 3(a), Section 4 or Section 5(a), 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 Bonds, or the type of business conducted; Packet Pg. 364 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 6 4916-3645-5085v2/200986-0003
(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 issuance of the Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; and (c) The amendment or waiver does not, in the opinion of nationally recognized bond counsel, materially impair the interests of the Holders or Beneficial Owners of the Bonds.
In the event of any amendment or waiver of a provision of this Disclosure Agreement, the City shall describe such amendment in the next Annual 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 City. In addition, if the amendment relates to the accounting principles to be followed in preparing financial statements, (i) notice of such change shall be given in the same manner as for a Listed Event under Section 5(c), and (ii) the Annual Report for the year in which the change is made should 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 9. Filings with the MSRB. All information, operating data, financial statements, notices and other documents provided to the MSRB in accordance with this Disclosure Agreement shall be provided in an electronic format prescribed by the MSRB and shall be accompanied by identifying information as prescribed by the MSRB.
Section 10. Additional Information. Nothing in this Disclosure Agreement shall be deemed to prevent the City 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 Report or notice of occurrence of a Listed Event, in addition to that which is required by this Disclosure Agreement. If the City chooses to include any information in any Annual Report or notice of occurrence of a Listed Event in addition to that which is specifically required by this Disclosure Agreement, the City shall have no obligation under this Disclosure Agreement to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event.
Section 11. Default. In the event of a failure of the City or the Dissemination Agent to comply with any provision of this Disclosure Agreement, the Trustee may (and, at the request of any Participating Underwriter or the Holders of at least 25% of the aggregate principal amount of Outstanding Bonds and upon provision of indemnification satisfactory to the Trustee, shall), or any Holder or Beneficial Owner of the Bonds may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the City or the Dissemination Agent, as the case may be, to comply with its obligations under this Disclosure Agreement. A default under 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 City or the Dissemination Agent to comply with this Disclosure Agreement shall be an action to compel performance hereunder.
Section 12. Duties, Immunities and Liabilities of Trustee and Dissemination Agent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Agreement, and the City agrees to indemnify and save the Dissemination Agent, its officers, directors, Packet Pg. 365 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 7 4916-3645-5085v2/200986-0003
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 attorneys’ fees) of defending against any claim of liability, but excluding any loss, expense and liabilities due to the Dissemination Agent’s negligence or willful misconduct. The obligations of the City under this Section 12 shall survive resignation or removal of the Dissemination Agent and payment of the Bonds.
Section 13. Notices. Any notices or communications to or among any of the parties to this Disclosure Agreement may be given as follows:
To the City: To the Dissemination Agent:
City of Redding
777 Cypress Avenue
Redding, California 96001
Attention: Finance Officer
Phone: (530) 225-4087
Fax: (530) 225-4324
U.S. Bank Trust Company, National Association
One California Street, Suite 1000
San Francisco, California 94111
Attention: Global Corporate Trust Services
Phone: (415) 677-3597
Fax: (415) 677-3769
Section 14. Beneficiaries. This Disclosure Agreement shall inure solely to the benefit of the City, the Trustee, the Dissemination Agent, the Participating Underwriter and the Holders and Beneficial Owners from time to time of the Bonds, and shall create no rights in any other person or entity.
[Remainder of page intentionally left blank.]
Packet Pg. 366 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 8 4916-3645-5085v2/200986-0003
Section 15. 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 REDDING, CALIFORNIA
By
City Manager
U.S. BANK TRUST COMPANY,
NATIONAL ASSOCIATION,
as Dissemination Agent
By
Authorized Officer
ACKNOWLEDGED:
U.S. BANK TRUST COMPANY,
NATIONAL ASSOCIATION, as Trustee
By
Authorized Officer
Packet Pg. 367 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 9 4916-3645-5085v2/200986-0003
EXHIBIT A
NOTICE TO MSRB OF FAILURE TO FILE ANNUAL REPORT
Name of Issuer: CITY OF REDDING
Name of Bond Issue: ELECTRIC SYSTEM REFUNDING REVENUE BONDS, SERIES 2026 Date of Issuance: _______, 2026
NOTICE IS HEREBY GIVEN that the City of Redding, California (the “City”) has not provided an Annual Report with respect to the above-named Bonds as required by Section 5.07 of the Indenture, dated as of July 1, 2026, by and between the City and U.S. Bank Trust Company, National Association, as trustee, and the Continuing Disclosure Agreement, dated July __, 2026, by and between the City and U.S. Bank Trust Company, National Association, as Dissemination Agent. The City anticipates that the Annual Report will be filed by ___________, 20__.
Dated: ______________, 20__
U.S. BANK TRUST COMPANY, NATIONAL
ASSOCIATION, as Dissemination Agent on behalf of
the City of Redding
By:
Authorized Officer
cc: City of Redding, California
Packet Pg. 368 Attachment: Continuing Disclosure Agreement (9.5(b)--Consider Authorization of Bond Refunding 2015A) Draft of 5/19/26
4909-8297-8690v6/200986-0003
PRELIMINARY OFFICIAL STATEMENT DATED JUNE __, 2026
NEW ISSUE – FULL BOOK-ENTRY ONLY RATING: Fitch: “[___]” (See “RATING” herein.)
In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the City, based upon an analysis of existing laws, regulations, rulings and court decisions, and assuming, among other matters, the accuracy of certain representations and compliance with certain covenants, interest on the 2026 Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 and is exempt from State of California personal income taxes. In the further opinion of Bond Counsel, interest on the 2026 Bonds is not a specific preference item for purposes of the federal individual alternative minimum tax.
Bond Counsel observes that interest on the 2026 Bonds included in adjusted financial statement income of certain corporations is not excluded from the federal corporate alternative minimum tax. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the 2026 Bonds. See “TAX MATTERS” herein.
$[Par]*
CITY OF REDDING
ELECTRIC SYSTEM REFUNDING REVENUE BONDS,
SERIES 2026
Dated: Date of Delivery Due: June 1, as shown on the inside cover This cover page contains certain information for general reference only. It is not intended to be a summary of the security or terms of this issue. Investors are advised to read the entire Official Statement to obtain information essential to the making of an informed investment decision. Capitalized terms used on this cover page and not otherwise defined shall have the meanings set forth herein.
The City of Redding, California (the “City”) is issuing its Electric System Refunding Revenue Bonds, Series 2026 (the “2026 Bonds”) for the purpose of providing funds to (i) refund the Redding Joint Powers Financing Authority’s outstanding Electric System Revenue Bonds, 2015 Series A and the related installment sale payments and (ii) pay costs of issuance of the 2026 Bonds, as further described herein. See “PLAN OF REFUNDING” herein.
The 2026 Bonds will be dated their date of delivery. Interest on the 2026 Bonds will be payable on June 1 and December 1 of each year, commencing December 1, 2026. The 2026 Bonds are being delivered in fully registered form and, when delivered, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York (“DTC”). DTC will act as securities depository for the 2026 Bonds. Individual purchases will be made in book-entry form only, in denominations of $5,000 principal amount or any integral multiple thereof. Payments of principal of and interest on, the 2026 Bonds are payable by the Trustee to DTC, which is obligated in turn to remit such principal and interest to its DTC Participants for subsequent disbursement to the beneficial owners of the 2026 Bonds, as described herein.
The 2026 Bonds are subject to redemption prior to maturity as described herein.
The 2026 Bonds are being issued pursuant to an Indenture, dated as of July 1, 2026 (the “Indenture”), by and between the City and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). The 2026 Bonds are payable from, and secured by, a pledge of and lien on Net Revenues of the City’s Electric System and moneys in the City’s Electric Revenue Fund on parity with the City’s outstanding and future Parity Obligations. As of June 2, 2026, the City had outstanding bonds and installment sale payments payable from Net Revenues of the Electric System, all constituting Parity Obligations, in the aggregate principal amount of $127.7 million (of which approximately $23.8 million is being refunded by the 2026 Bonds). The City may hereafter issue or incur additional Parity Obligations pursuant to the terms of the Indenture. Maintenance and Operation Costs of the Electric System (including certain take-or-pay obligations under contracts with joint powers agencies) are payable by the City from Revenues of the Electric System prior to the payment of Parity Obligations.
The 2026 Bonds are special obligations of the City payable solely from Net Revenues of the Electric System and moneys in the Electric Revenue Fund as provided in the Indenture. The 2026 Bonds do not constitute a debt of the City or of the State of California or of any political subdivision thereof within the meaning of any constitutional or statutory debt limitation or restriction. The General Fund of the City is not liable and neither the faith and credit nor the taxing power of the City is pledged for the payment of the principal of the 2026 Bonds or the interest on the 2026 Bonds or the performance or satisfaction of any other obligation of the City under the Indenture.
MATURITY SCHEDULE
(see inside front cover)
The 2026 Bonds will be offered when, as and if issued and received by the Underwriter, subject to the approval of legality by Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the City, and certain other conditions. Certain legal matters will be passed upon for the City by the City Attorney of the City of Redding, and for the Underwriter by Norton Rose Fulbright US LLP. Stradling Yocca Carlson & Rauth LLP is acting as Disclosure Counsel to the City in connection with the 2026 Bonds. It is expected that the 2026 Bonds will be available for delivery through the DTC book-entry system in New York, New York by Fast Automated Securities Transfer (FAST) on or about July __, 2026.
* Preliminary, subject to change.
This Preliminary Official Statement and the information contained herein are subject to completion and amendment. Under no circumstances shall this Preliminary Official Statement constitute an offer to sell or a solicitation of an offer to buy nor shall there be any sale of these securities in any jurisdiction in which such offer, solicitation or sale would be unlawful prior to registration, qualification or filing under the securities laws of any such jurisdiction.
Packet Pg. 369 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4909
-8297-8690v6/200986-0003
J.P. Morgan
Dated: ___________, 2026
Packet Pg. 370 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4909-8297-8690v6/200986-0003
$[Par]*
CITY OF REDDING
ELECTRIC SYSTEM REFUNDING REVENUE BONDS,
SERIES 2026
MATURITY SCHEDULE
$[_______]* Serial 2026 Bonds
Maturity Date
(June 1)*
Principal
Amount*
Interest
Rate
Price or
Yield
CUSIP†
(Base No. 75728T)
$_______* ____% Term 2026 Bonds due June 1, 20__, Price or Yield ______% ; CUSIP†: 75728T___ $_______* ____% Term 2026 Bonds due June 1, 20__, Price or Yield ______% ; CUSIP†: 75728T___ ___________________________________
* Preliminary, subject to change.
† CUSIP® is a registered trademark of the American Bankers Association. CUSIP data herein are provided by CUSIP Global Services, managed by FactSet Research Systems Inc. on behalf of the American Bankers Association. CUSIP numbers have been assigned by an independent company not affiliated with the City or the Underwriter and are included solely for the convenience of the holders of the 2026 Bonds. Neither of the City nor the Underwriter is responsible for the selection or use of these CUSIP numbers and no representation is made as to their correctness on the 2026 Bonds or as indicated above. The CUSIP number for a specific maturity is subject to being changed after the issuance of the 2026 Bonds as a result of various subsequent actions including, but not limited to, a refunding in whole or in part of such maturity or as a result of the procurement of secondary market portfolio insurance or other similar enhancement by investors that is applicable to all or a portion of the 2026 Bonds.
Packet Pg. 371 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4909-8297-8690v6/200986-0003
CITY OF REDDING
777 Cypress Avenue
Redding, California 96001
CITY COUNCIL
Mike Littau, Mayor
Dr. Paul Dhanuka, Vice Mayor
Erin Resner, Mayor Pro Tempore
Tenessa Audette, Council Member
Jack Munns, Council Member
CITY OFFICIALS
William S. Tarbox
City Manager
Benjamin L. Stock
Interim City Attorney
Nicholas Zettel
Director of Electric Utility
Joseph Bowers
Assistant Electric Utility Director, Resources
SPECIAL SERVICES
Orrick, Herrington & Sutcliffe LLP
San Francisco, California
Bond Counsel
Stradling Yocca Carlson & Rauth LLP
Newport Beach, California
Disclosure Counsel
PFM Financial Advisors LLC
Los Angeles, California
Municipal Advisor
U.S. Bank Trust Company, National Association
Phoenix, Arizona
Trustee
Packet Pg. 372 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4909-8297-8690v6/200986-0003
No dealer, broker, salesperson or other person has been authorized by the City or the Underwriter to give any information or to make any representations other than those contained herein and, if given or made, such other information or representations must not be relied upon as having been authorized by the foregoing.
This Official Statement does not constitute an offer to sell or the solicitation of an offer to buy nor shall there be any sale of the 2026 Bonds in any jurisdiction in which it is unlawful to make such offer, solicitation or sale. This Official Statement is not to be construed as a contract with the purchasers of the 2026 Bonds.
The information set forth herein has been furnished by the City and other sources which are believed to be reliable, but it is not guaranteed as to accuracy or completeness by, and is not to be construed as a representation by, the Underwriter. Statements contained in this Official Statement which involve estimates, forecasts or matters of opinion, whether or not expressly so described herein, are intended solely as such and are not to be construed as representations of fact. The information and expressions of opinions herein are subject to change without notice and neither delivery of this Official Statement nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the City or the Electric System since the date hereof. This Official Statement, including any supplement or amendment hereto, is intended to be deposited with the Municipal Securities Rulemaking Board through the Electronic Municipal Market Access (EMMA) website.
The Underwriter has provided the following sentence for inclusion in this Official Statement: The Underwriter has reviewed the information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applicable to the facts and circumstances of this transaction, but the Underwriter does not guarantee the accuracy or completeness of such information.
IN CONNECTION WITH THE OFFERING OF THE 2026 BONDS THE UNDERWRITER
MAY OVERALLOT OR EFFECT TRANSACTIONS THAT STABILIZE OR MAINTAIN THE MARKET PRICE OF THE 2026 BONDS AT LEVELS ABOVE THOSE WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME.
__________________________
CAUTIONARY STATEMENTS REGARDING
FORWARD-LOOKING STATEMENTS IN
THIS OFFICIAL STATEMENT
Certain statements included or incorporated by reference in this Official Statement and the Appendices hereto constitute “forward-looking statements.” Such statements are generally identifiable by the terminology used such as “plan,” “expect,” “estimate,” “budget” or other similar words. Such forward-looking statements include, but are not limited to, certain statements contained in the information under the captions “THE ELECTRIC SYSTEM,” “RATE REGULATION,” and “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY” in this Official Statement. Forward-looking statements in this Official Statement are subject to risks and uncertainties, including particularly those relating to natural gas costs and availability, wholesale and retail electric energy and capacity prices, federal and state legislation and regulations, the impact of weather on the energy market, industry restructuring, changes in consumer electricity demand and use patterns, and the economy of the service area of the City’s Electric System.
The achievement of any results or the realization of other expectations contained in such forwardlooking statements involve known and unknown risks, uncertainties and other factors that may cause actual results, performance or achievements to be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. The City does not plan to issue any updates or revisions to those forward-looking statements.
The City maintains a website. However, the information presented therein is not part of this Official Statement and should not be relied upon in making investment decisions with respect to the 2026 Bonds.
References to website addresses presented herein are for informational purposes only and may be in the form of a hyperlink solely for the reader’s convenience. Unless specified otherwise, such websites and the information or links contained therein are not incorporated into, and are not part of, this Official Statement for purposes of, and as that term is defined in, S.E.C. Rule 15c2-12(b)(5).
Packet Pg. 373 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A)
TABLE OF CONTENTS
Page
i
4909-8297-8690v6/200986-0003
INTRODUCTION .................................................................................................................................3 Purpose; Authority for Issuance.........................................................................................................3 The City .............................................................................................................................................3 Security and Sources of Payment for the 2026 Bonds.......................................................................4 Rate Covenant....................................................................................................................................5 Continuing Disclosure .......................................................................................................................5 Other Matters.....................................................................................................................................6 PLAN OF REFUNDING.......................................................................................................................6 General...............................................................................................................................................6 Refunding of 2015 RJPFA Electric System Bonds ...........................................................................6 ESTIMATED SOURCES AND USES OF FUNDS .............................................................................8 THE 2026 BONDS ................................................................................................................................8 General...............................................................................................................................................8 Redemption........................................................................................................................................9 SECURITY AND SOURCES OF PAYMENT FOR THE 2026 BONDS..........................................10 Pledge Under the Indenture .............................................................................................................10 Allocation of Revenues Under the Indenture...................................................................................11 Flow of Funds Under the Indenture .................................................................................................12 Rate Covenant..................................................................................................................................13 No Debt Service Reserve Fund........................................................................................................14 Outstanding Electric System Revenue Obligations.........................................................................14 Additional Electric System Revenue Obligations............................................................................16 Investment of Funds.........................................................................................................................17 Limitations on Remedies .................................................................................................................17 THE ELECTRIC SYSTEM.................................................................Error! Bookmark not defined.
CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY..... Error! Bookmark not defined.
CONSTITUTIONAL LIMITATIONS IN CALIFORNIA AFFECTING FEES AND CHARGES ..............................................................................................................Error! Bookmark not defined.
TAX MATTERS..................................................................................................................................67 LITIGATION.......................................................................................................................................69 RATING ..............................................................................................................................................70 CONTINUING DISCLOSURE...........................................................................................................70 UNDERWRITING ..............................................................................................................................71 CERTAIN RELATIONSHIPS ............................................................................................................71 CERTAIN LEGAL MATTERS...........................................................................................................71 MUNICIPAL ADVISOR.....................................................................................................................72 AUDITED FINANCIAL STATEMENTS ..........................................................................................72 EXECUTION AND DELIVERY........................................................................................................73 Packet Pg. 374 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A)
TABLE OF CONTENTS
(continued)
Page
ii
4909-8297-8690v6/200986-0003
APPENDIX A EXCERPTS OF THE AUDITED FINANCIAL STATEMENTS OF THE CITY FOR THE FISCAL YEAR ENDED JUNE 30, 2025..................................A-1 APPENDIX B CERTAIN INFORMATION CONCERNING THE CITY OF REDDING..........B-1 APPENDIX C BOOK-ENTRY ONLY SYSTEM ........................................................................C-1 APPENDIX D SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE...................D-1 APPENDIX E PROPOSED FORM OF CONTINUING DISCLOSURE AGREEMENT ........... E-1 APPENDIX F PROPOSED FORM OF OPINION OF BOND COUNSEL ................................. F-1 APPENDIX G DEBT SERVICE SCHEDULE .............................................................................G-1 Packet Pg. 375 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4909-8297-8690v6/200986-0003
OFFICIAL STATEMENT
$[Par]*
CITY OF REDDING
ELECTRIC SYSTEM REFUNDING REVENUE BONDS,
SERIES 2026
_________________________
INTRODUCTION
This Introduction is subject in all respects to the more complete information contained elsewhere in this Official Statement, and the offering of the 2026 Bonds to potential investors is made only by means of the entire Official Statement. Terms used in this Introduction or otherwise in this Official Statement and not otherwise defined herein shall have the respective meanings assigned to them in Appendix D hereto.
Purpose; Authority for Issuance
The purpose of this Official Statement, which includes the cover page and appendices hereto, is to set forth certain information concerning the issuance and sale of $[Par]*principal amount of City of Redding Electric System Refunding Revenue Bonds, Series 2026 (the “2026 Bonds”). The 2026 Bonds are being issued pursuant to Articles 10 and 11, Chapter 3, Part 1, Division 2, Title 5 of the Government Code of the State of California (the “Refunding Act”), and an Indenture, dated as of July 1, 2026 (the “Indenture”), by and between the City of Redding, California (the “City”) and U.S.
Bank Trust Company, National Association, as trustee (the “Trustee”).
The 2026 Bonds are being issued for the purpose of providing funds to (i) refund the Redding Joint Powers Financing Authority’s (the “Authority”) outstanding Electric System Revenue Bonds, 2015 Series A (the “Refunded 2015A Bonds”) and the related installment sale payments payable by the City to the Authority pursuant to the 2015 Installment Sale Agreement, dated as of December 1, 2015 (the “2015A Installment Sale Agreement”), by and between the Authority and the City, and (ii) pay costs of issuance of the 2026 Bonds, as further described herein. See “PLAN OF REFUNDING.”
The City
The City is a general law city of the State of California, comprising approximately 60 square miles, located at the northern end of the Sacramento Valley, approximately 160 miles north of Sacramento and 230 miles northeast of San Francisco. As a general law city, the City has the power to furnish electric utility service to its inhabitants. In connection therewith, the City has the powers of eminent domain, to contract, to construct works, to fix rates and charges for commodities or services furnished and to incur indebtedness. To provide electric service within its service area (which is coterminous with the City’s corporate city boundaries), the City owns and operates an electric system (the “Electric System” as more fully defined in Appendix D) that includes generation, transmission and distribution facilities. The City also purchases power and transmission service from others. For the Fiscal Year ended June 30, 2025, the City Electric System served approximately 45,591 customer accounts, had total sales of approximately 770.5 million kWh and had a peak demand of 240.9 MW.
* Preliminary, subject to change.
Packet Pg. 376 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 4 4909-8297-8690v6/200986-0003
See “THE ELECTRIC SYSTEM” and “APPENDIX B – CERTAIN INFORMATION CONCERNING THE CITY OF REDDING.”
Security and Sources of Payment for the 2026 Bonds
The 2026 Bonds are special obligations of the City payable solely from and secured solely by a pledge of and lien on Net Revenues of the Electric System and all moneys on deposit in the Electric Revenue Fund of the City. The pledge of and lien on Net Revenues of the Electric System and amounts on deposit in the Electric Revenue Fund for the payment of the 2026 Bonds is on parity with and equal to the charge and lien upon such Net Revenues and amounts on deposit in the Electric Revenue Fund securing all Parity Obligations (hereinafter defined) heretofore or hereafter issued or incurred by the City as described herein.
As of June 2, 2026, the City had outstanding Parity Obligations in the aggregate principal amount of approximately $127.7 million, comprised of (i) City of Redding Electric System Refunding Revenue Bonds, Series 2017 (the “2017 Electric System Bonds”) outstanding in the principal amount of $22.9 million, (ii) City of Redding Electric System Refunding Revenue Bonds, Series 2018 (the “2018 Electric System Bonds”) outstanding in the principal amount of $15.0 million, (iii) installment sale payments related to the Authority Electric System Revenue Bonds, 2015 Series A (the “2015 RJPFA Electric System Bonds”) outstanding in the principal amount of $23.8 million (all of which is being refunded by the 2026 Bonds) and (iv) installment sale payments related to the Authority Electric System Revenue Bonds, 2025 Series A (the “2025 RJPFA Electric System Bonds”) outstanding in the principal amount of $66.0 million.
The City may issue or incur additional obligations payable from Net Revenues and moneys on deposit in the Electric Revenue Fund on a parity with the 2026 Bonds, the 2017 Electric System Bonds, the 2018 Electric System Bonds, and the installment sale payments relating to the 2025 RJPFA Electric System Bonds, subject to the terms and conditions set forth in the Indenture. All obligations heretofore or hereafter issued or incurred by the City the payment of which constitutes a charge and lien on the Net Revenues and moneys in the Electric Revenue Fund equal to and on a parity with the charge and lien on the Net Revenues and moneys in the Electric Revenue Fund for the payment of the 2026 Bonds are herein referred to as “Parity Obligations.” The City has, and may in the future, also issue or incur obligations the payments under and pursuant to which are payable from Net Revenues, subject and subordinate to the 2026 Bonds and to all other Parity Obligations (“Subordinate Obligations”). The City and the Authority have entered into an Amended and Restated Revolving Credit Agreement, dated as of May 1, 2023 (the “Revolving Credit Agreement”) with U.S. Bank National Association (the “Credit Bank”), under which the Credit Bank has agreed to advance funds to the Authority, from time to time, in an amount up to $25.0 million, for the benefit of the City Electric System. The term of the Revolving Credit Agreement extends to November 1, 2028, unless extended or earlier terminated pursuant to its terms.
Borrowings under the Revolving Credit Agreement are payable from, and secured by, certain installment sale payments required to be made by the City to the Authority under the terms of a Subordinate Installment Sale Agreement, dated as of October 1, 2020 (the “Subordinate Installment Sale Agreement”), by and between the City and the Authority, the installment sale payments to be made by the City under which Subordinate Installment Sale Agreement constitute Subordinate Obligations. As of June 2, 2026, there were no outstanding borrowings by the City under the Revolving Credit Agreement.
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As of June 2, 2026, the City had outstanding approximately $19.9 million principal amount of take-or-pay obligations related to debt of the joint powers agencies in which it participates, which obligations constitute Maintenance and Operation Costs of the Electric System and are payable from Revenues of the Electric System prior to the 2026 Bonds and other Parity Obligations. The City may incur additional obligations pursuant to its agreements with such joint power agencies in which it now, or in the future may, participate or enter into other contacts or leases for the purchase of facilities, properties, structures or works or electric output, capacity or other electrical services for the Electric System which are Maintenance and Operation Costs of the Electric System, payable from Revenues of the Electric System prior to the 2026 Bonds and other Parity Obligations.
See “SECURITY AND SOURCES OF PAYMENT FOR THE 2026 Bonds – Outstanding Electric System Revenue Obligations” and “– Additional Electric System Revenue Obligations.” The 2026 Bonds are special obligations of the City payable solely from Net Revenues of the Electric System and moneys in the Electric Revenue Fund as provided in the Indenture.
The 2026 Bonds do not constitute a debt of the City or of the State of California or of any political subdivision thereof within the meaning of any constitutional or statutory debt limitation or restriction. The General Fund of the City is not liable and neither the faith and credit nor the taxing power of the City is pledged for the payment of the principal of the 2026 Bonds or the interest on the 2026 Bonds or the performance or satisfaction of any other obligation of the City under the Indenture.
Rate Covenant
Pursuant to the Indenture, the City has covenanted to fix, prescribe and collect rates and charges for the services, facilities and electricity of the Electric System during each Fiscal Year which will be at least sufficient to yield (a) Adjusted Annual Revenues for such Fiscal Year at least equal to the sum of the following for such Fiscal Year: (i) Maintenance and Operation Costs, (ii) Adjusted Annual Debt Service, and (iii) all other payments required to meet any other obligations of the City which are charges, liens or encumbrances upon or payable from the Electric Revenue Fund, including all amounts owing under Subordinate Obligations; and (b) Adjusted Annual Net Revenues for such Fiscal Year equal to at least 110% of the Adjusted Annual Debt Service for such Fiscal Year. See “SECURITY AND SOURCES OF PAYMENT FOR THE 2026 BONDS – Rate Covenant.”
Continuing Disclosure
The City has covenanted for the benefit of the holders and beneficial owners of the 2026 Bonds to provide certain financial information and operating data relating to the City and the Electric System by not later than 270 days following the end of the City’s Fiscal Year (which Fiscal Year presently ends June 30) (the “Annual Report”), commencing with the report for the 2025-26 Fiscal Year, and to provide notices of the occurrence of certain enumerated events. See “CONTINUING DISCLOSURE.” These covenants have been made in order to assist the Underwriter in complying with S.E.C. Rule 15c2-12(b)(5) (the “Rule”). See also “CONTINUING DISCLOSURE” and “APPENDIX E – PROPOSED FORM OF CONTINUING DISCLOSURE AGREEMENT.” Packet Pg. 378 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 6 4909-8297-8690v6/200986-0003
Other Matters
This Official Statement includes summaries of the terms of the 2026 Bonds, the Indenture, the Continuing Disclosure Agreement and certain contracts and other arrangements for the supply of capacity and energy. The summaries of and references to all documents, statutes, reports and other instruments referred to herein do not purport to be complete, comprehensive or definitive, and each such summary and reference is qualified in its entirety by reference to each document, statute, report or instrument. The capitalization of any word not conventionally capitalized, or otherwise defined herein, indicates that such word is defined in a particular agreement or other document and, as used herein, has the meaning given it in such agreement or document.
Copies of the Indenture and the Continuing Disclosure Agreement are available for inspection at the offices of the Trustee or the Redding Electric Utility Department (the “Electric Utility Department”), and will be available upon request and payment of duplication costs from the Trustee.
Additional information regarding the Official Statement may be obtained by contacting the Trustee or contacting the City at: City of Redding, 777 Cypress Avenue, Redding, California 96001, Attention: Assistant Electric Utility Director, Resources.
PLAN OF REFUNDING
General
The 2026 Bonds are being issued for the purpose of providing funds to (i) refund the Authority’s 2015 RJPFA Electric System Bonds and the related installment sale payments payable by the City pursuant to the 2015A Installment Sale Agreement and (ii) pay costs of issuance of the 2026 Bonds
Refunding of 2015 RJPFA Electric System Bonds
The 2015 RJPFA Electric System Bonds were issued on December 17, 2015, in the aggregate principal amount of $37,955,000 to (i) finance the costs of design, acquisition and construction of a new administrative building for the City’s electric utility and other related facilities; (ii) prepaying and refunding the City’s then outstanding Electric System revenue certificates of participation and (iii) pay costs of issuance of the 2015 RJPFA Electric System Bonds. The 2015 RJPFA Electric System Bonds are primarily payable from installment sale payments made by the City under the 2015A Installment Sale Agreement. As of the date hereof, $23,750,000 aggregate principal amount of the 2015 RJPFA Electric System Bonds remain outstanding. See also “SECURITY AND SOURCES OF PAYMENT FOR THE 2026 Bonds – Outstanding Electric System Revenue Obligations – Parity Obligations.” A portion of the proceeds of the 2026 Bonds will be used to refund the outstanding principal amount of the 2015 RJPFA Electric System Bonds maturing on and after June 1, 2027. The Refunded 2015A Bonds will be called for redemption on July __, 2026 (the “Redemption Date”), the date of issuance of the 2026 Bonds.
The refunding of the Refunded 2015A Bonds is being undertaken to achieve net present value and debt service savings. The following table details the maturity dates and principal amounts of the 2015 RJPFA Electric System Bonds to be refunded.
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Refunded 2015A Bonds
Maturity Date
(June 1)
CUSIP†
(Base No.:
75728L)
Outstanding
Principal
Amount to be
Prepaid Interest Rate
Redemption
Date
Redemption
Price
2027 BD7 $ 2,530,000 5.000% July __, 2026 100%
2027 BE5 2,650,000 5.000 July __, 2026 100
2029 BF2 2,790,000 5.000 July __, 2026 100
2030 BG0 2,925,000 5.000 July __, 2026 100
2031 BH8 2,345,000 5.000 July __, 2026 100
2032 BJ4 2,465,000 5.000 July __, 2026 100
2033 BK1 2,590,000 3.625 July __, 2026 100
2034 BL9 2,680,000 3.650 July __, 2026 100
2035 BM7 2,775,000 3.750 July __, 2026 100
Total $23,750,000
__________________
† CUSIP® is a registered trademark of American Bankers Association. CUSIP® data herein are provided by CUSIP Global Services, managed by FactSet Research Systems Inc. on behalf of American Bankers Association. Neither the City nor the Underwriters is responsible for the selection or correctness of the CUSIP numbers set forth herein.
The refunding of the Refunded 2015A Bonds will be effected by depositing a portion of the proceeds of the 2026 Bonds into the Refunding Fund created under the Indenture. Amounts deposited in the Refunding Fund will be sufficient to pay on the Redemption Date the redemption price (i.e., 100% of the principal amount) of the Refunded 2015A Bonds plus accrued interest thereon to such Redemption Date. On the Redemption Date, the Trustee will transfer all money in the Refunding Fund to U.S. Bank Trust Company, National Association, as trustee under the Trust Agreement, dated as of December 1, 2015 (the “2015A Trust Agreement”), by and between the Authority and U.S. Bank Trust Company, National Association, as successor trustee, pursuant to which the Refunded 2015A Bonds were issued in accordance with a Written Order of the City to pay the redemption price of the Refunded 2015A Bonds.
Upon such deposit, the liability of the Authority with respect to the Refunded 2015A Bonds will cease and the Refunded 2015A Bonds will no longer be outstanding under the 2015A Trust Agreement. In addition, upon such deposit, the liability of the City with respect to the installment sale payments relating to the Refunded Bonds payable under the 2015 Installment Sale Agreement will cease in accordance with the terms of the 2015 Installment Sale Agreement.
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ESTIMATED SOURCES AND USES OF FUNDS
The estimated sources and uses of funds in connection with the 2026 Bonds, are as follows:
Sources:
Principal Amount of 2026 Bonds........................................... $ [Net] Original Issue [Premium/Discount] ..............................
Total Sources............................................................... $ Uses:
Deposit to Refunding Fund(1).................................................. $ Costs of Issuance (2)................................................................
Total Uses.................................................................... $ __________________
(1) To be used to pay the redemption price of the Refunded 2015A Bonds on the Redemption Date. See “PLAN OF REFUNDING–Refunding of 2015 RJPFA Electric System Bonds.” (1) Includes Underwriter’s discount, legal fees, fees of the Trustee, municipal advisory fees, rating agency fees, printing costs and other miscellaneous expenses.
THE 2026 BONDS
The following is a summary of certain provisions of the 2026 Bonds. Reference is made to the 2026 Bonds for the complete text thereof and to the Indenture for a more detailed description of such provisions. The discussion herein is qualified by such reference. See “APPENDIX D – SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE.”
General
The 2026 Bonds will be issued in the aggregate principal amount set forth on the inside cover page of this Official Statement. The 2026 Bonds are being delivered in fully registered form, and when delivered, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York (“DTC”). DTC will act as securities depository for the 2026 Bonds.
Principal of and interest on the 2026 Bonds are payable by the Trustee to DTC, which is obligated in turn to remit such principal and interest to its DTC Participants for subsequent disbursement to the beneficial owners of the 2026 Bonds. See “APPENDIX C – BOOK-ENTRY ONLY SYSTEM.” The 2026 Bonds will be dated the date of delivery thereof. Ownership interests in the 2026 Bonds will be in $5,000 denominations or any integral multiple thereof. Interest on the 2026 Bonds is payable on June 1 and December 1 of each year commencing December 1, 2026 (each, an “Interest Payment Date”), calculated on the basis of a 360-day year and twelve 30-day months. The 2026 Bonds will mature on the dates and in the principal amounts, and the interest thereon shall be computed at the per annum interest rates, all as set forth on the inside cover page of this Official Statement.
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Redemption
Optional Redemption.* The 2026 Bonds maturing on and after June 1, 20__ are subject to optional redemption by the City prior to their respective stated maturity dates, as a whole or in part from such maturity dates determined by the City, on any date on or after June 1, 20__, from any source of available funds, at a redemption price equal to the principal amount of the 2026 Bonds to be redeemed plus accrued interest to the redemption date, without premium.
Mandatory Redemption.
* The term 2026 Bonds maturing on June 1, 20___ are subject to mandatory redemption prior to maturity, in part by lot, commencing on June 1, 20___ and on each June 1 thereafter to and including June 1, 20___, at a redemption price equal to the principal amount of the 2026 Bonds to be redeemed, together with accrued interest thereon to the date fixed for redemption, without premium, according to the following schedule (subject to modification in the event of optional redemption as described above):
2026 Bonds maturing
on June 1, 20__
Redemption Date
(June 1)
Principal
Amount
†
_______________
† Final Maturity.
Selection of 2026 Bonds for Redemption. If less than all of the 2026 Bonds are to be called for redemption, the City may select the maturities of the 2026 Bonds to be redeemed. Subject to DTC’s procedures relating to the selection of bonds for redemption (see “APPENDIX C – BOOKENTRY ONLY SYSTEM”), if less than all of the 2026 Bonds of any one maturity date are to be redeemed at any one time, the Trustee shall, select the 2026 Bonds or portions thereof of such maturity date not previously called for redemption to be redeemed in integral multiples of $5,000 randomly by lot in any manner which the Trustee deems appropriate and fair.
Notice of Redemption of 2026 Bonds. Notice of redemption of any 2026 Bonds shall be given by the Trustee by mail, first-class postage prepaid, or by electronic means of communication, not less than 20 nor more than 60 days prior to the redemption date to the Owners of all 2026 Bonds selected for redemption in whole or in part, and to all securities depositories and securities information services selected by the City to comply with custom or the rules of any securities exchange or commission or brokerage board or otherwise as may be determined by the City in its sole discretion. Neither failure to receive any such notice nor any immaterial defect contained therein shall affect the sufficiency or validity of the proceedings taken in connection with any such redemption. So long as DTC is acting as securities depository for the 2026 Bonds, notice of redemption will be given in accordance with DTC procedures only to DTC or its nominee, not to the beneficial owners of the 2026 Bonds. See “APPENDIX C – BOOK-ENTRY ONLY SYSTEM.”
* Preliminary; subject to change.
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In the event of an optional redemption of 2026 Bonds, the Trustee shall give notice of redemption only after receipt of a Written Order of the City; provided, that if the City shall not have deposited or otherwise made available to the Trustee the money required for the payment of the redemption price of the 2026 Bonds to be redeemed at the time of such mailing, such notice of redemption shall state that the redemption is expressly conditioned upon the timely deposit of sufficient funds therefor with the Trustee.
Effect of Redemption of 2026 Bonds. If notice of redemption has been duly given and money for the payment of the principal of and redemption premiums, if any on, together with accrued interest to the redemption date on, the 2026 Bonds or portions thereof so called for redemption is held by the Trustee, then on the redemption date designated in such notice, such 2026 Bonds or such portions thereof shall become due and payable, and from and after the date designated for redemption, interest on the 2026 Bonds or portions thereof so called for redemption shall cease to accrue and the Owners of such 2026 Bonds shall have no rights in respect thereof except to receive payment of the principal or such portions thereof and the redemption premiums, if any, thereon and the interest accrued thereon to the redemption date.
SECURITY AND SOURCES OF PAYMENT FOR THE 2026 BONDS
Pledge Under the Indenture
The 2026 Bonds are special obligations of the City payable solely from and secured solely by a pledge of and lien on “Net Revenues” (as defined below) of the Electric System and all moneys on deposit in the Electric Revenue Fund. The pledge of and lien on Net Revenues of the Electric System and amounts on deposit in the Electric Revenue Fund for the payment of the 2026 Bonds is on parity with and equal to the charge and lien upon such Net Revenues and amounts on deposit in the Electric Revenue Fund securing the obligation of the City to pay the Parity Obligations (consisting of electric system refunding bonds and installment sale payments relating to the Authority bonds) outstanding as of June 2, 2026 in the aggregate principal amount of $127.7 million (of which approximately $23.8 million is being refunded by the 2026 Bonds). See “– Outstanding Electric System Revenue Obligations – Outstanding Parity Obligations” below. The City may issue or incur additional Parity Obligations payable from Net Revenues of the Electric System on parity with the 2026 Bonds and the outstanding Parity Obligations subject to the terms of the Indenture. See “– Outstanding Electric System Revenue Obligations” and “– Additional Electric System Revenue Obligations” below.
The term “Net Revenues” is defined in the Indenture to mean, for any period of time in question, the Revenues during such period less the Maintenance and Operation Costs during such period.
“Revenues” is defined in the Indenture to consist of all gross income and revenue received or receivable by the City from the ownership or operation of the Electric System, including all rates and charges received by the City for the Electric Service and the other services and facilities of the Electric System, all proceeds of insurance covering business interruption loss relating to the Electric System and all other income and revenue howsoever derived by the City from the ownership or operation of the Electric System or otherwise arising from the Electric System, including all Payment Agreement Receipts, and all income from the deposit or investment of any money in the Electric Revenue Fund, but excluding (i) proceeds of taxes and (ii) refundable deposits made to establish credit and advances or contributions in aid of construction and line extension fees. See “APPENDIX D –SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE –Definitions.” Packet Pg. 383 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 11 4909-8297-8690v6/200986-0003
“Maintenance and Operation Costs” is defined in the Indenture to mean the costs paid or incurred by the City for maintaining and operating the Electric System, including, but not limited to, (a) all costs of electric energy and power generated or purchased by the City for resale, costs of transmission, fuel supply and water supply in connection with the foregoing, (b) all expenses of management and repair and other expenses necessary to maintain and preserve the Electric System in good repair and working order, (c) all administrative costs of the City that are charged directly or apportioned to the operation of the Electric System, such as salaries and wages of employees, overhead, taxes (if any) and insurance premiums, (d) all other reasonable and necessary costs of the City or charges required to be paid by it to comply with the terms of the Indenture or of any resolution authorizing the execution of the Indenture or of any resolution authorizing the issuance or incurrence of any Parity Obligations or of such Parity Obligations, such as compensation, reimbursement and indemnification of the trustee, remarketing agent or surety costs for the 2026 Bonds or other Parity Obligations, letter of credit fees relating to Parity Obligations, fees and expenses of Independent Certified Public Accountants, (e) all amounts required to be paid by the City under contracts with a joint powers agency for the purchase of capacity, energy, transmission capability or any other commodity or service in connection with the foregoing, which contract requires payments to be made by the City thereunder to be treated as maintenance and operation costs of the Electric System (see “– Outstanding Electric System Revenue Obligations – Take-or-Pay Power Sales Contracts” below), (f) all deposits to be made to the Rebate Fund pursuant to the Tax Certificate and all deposits in comparable accounts established with respect to Parity Obligations required to be deposited pursuant to the proceedings authorizing such Parity Obligations, and (g) any other cost or expense which, in accordance with Generally Accepted Accounting Principles, is to be treated as a cost of operating or maintaining the Electric System; but excluding in all cases, depreciation, replacement and obsolescence charges or reserves therefor and amortization of intangibles. See “APPENDIX D – SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE – Definitions.”
The 2026 Bonds are special obligations of the City payable solely from Net Revenues of the Electric System and moneys in the Electric Revenue Fund as provided in the Indenture.
The 2026 Bonds do not constitute a debt of the City or of the State of California or of any political subdivision thereof within the meaning of any constitutional or statutory debt limitation or restriction. The General Fund of the City is not liable and neither the faith and credit nor the taxing power of the City is pledged for the payment of the principal of the 2026 Bonds or the interest on the 2026 Bonds or the performance or satisfaction of any other obligation of the City under the Indenture.
Allocation of Revenues Under the Indenture
Pursuant to the Indenture, the City agrees and covenants that all Revenues received by it shall be deposited when and as received in the “City of Redding Electric Revenue Fund” (the “Electric Revenue Fund”) established by the City. The City shall pay all Maintenance and Operation Costs (including amounts reasonably required to be set aside in contingency reserves for Maintenance and Operation Costs the payment of which is not then immediately required) from the Electric Revenue Fund as they become due and payable, and all remaining money on deposit in the Electric Revenue Fund shall be set aside and deposited by the City at the following times:
On or before the fourth Business Day before each Interest Payment Date, the City shall, from the money in the Electric Revenue Fund, transfer to the Trustee for deposit in the “City of Redding 2026 Electric System Refunding Revenue Bonds Debt Service Fund” (the “Debt Service Fund”) Packet Pg. 384 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 12 4909-8297-8690v6/200986-0003
(which fund the Trustee shall establish and maintain), a sum equal to the amount of interest becoming due on the 2026 Bonds on the next succeeding Interest Payment Date, plus, if a principal payment is due on such succeeding Interest Payment Date, the amount of principal becoming due on the 2026 Bonds on the next succeeding June 1; provided, no deposit need be made in the Debt Service Fund if the amount available and contained therein is at least equal to the amount of interest becoming due on the 2026 Bonds on the next succeeding June 1 or December 1, as the case may be, plus, if a principal payment is due on such succeeding Interest Payment Date, the amount of principal becoming due on the 2026 Bonds on the next succeeding June 1.
The City shall also, from such remaining moneys in the Electric Revenue Fund, pay to the party entitled thereto or transfer or cause to be transferred to any applicable debt service or other payment fund or account for any Parity Obligations, without preference or priority between transfers made as described in this sentence and the transfers made for the payment of the 2026 Bonds as described in the immediately preceding paragraph, and in the event of any insufficiency of such moneys ratably without any discrimination or preference, on the dates specified in the proceedings relating to such Parity Obligations, the sum or sums required to be paid or deposited in such debt service or other payment fund or account with respect to principal, premium, if any, and interest on Parity Obligations (or in the case of Parity Payment Agreements, the net payments due) in accordance with the terms of such Parity Obligations.
After making the foregoing deposits and transfers, the City shall apply any remaining money in the Electric Revenue Fund for any lawful purpose of the City, including for the payment of any obligations of the City, the payments under and pursuant to which are payable from Net Revenues, subject and subordinate to the 2026 Bonds and to all Parity Obligations (“Subordinate Obligations”) in accordance with the instruments authorizing such Subordinate Obligations; provided, however, that no moneys in the Electric Revenue Fund shall be applied to any purpose not related to the expansion of the facilities or business of the Electric System or replacement of facilities thereof, including the payment of any Subordinate Obligations, in any Fiscal Year unless amounts remaining on deposit in the Electric Revenue Fund shall be sufficient to make the remaining transfers hereinabove described required to be made in such Fiscal Year with respect to the 2026 Bonds and all Parity Obligations.
The City shall distribute Net Revenues available for the payment of the Outstanding 2026 Bonds and payments on all outstanding Parity Obligations on a pro rata basis without regard to whether each such Parity Obligation has a funded debt service reserve or a surety bond or other similar funding instrument.
Flow of Funds Under the Indenture
Pursuant to the Indenture, the Trustee will establish the Debt Service Fund for the receipt of moneys transferred by the City from the Electric Revenue Fund as described above. The moneys in the Debt Service Fund shall be set aside by the Trustee in the following respective special accounts within the Debt Service Fund (each of which is created under the Indenture and each of which the Trustee agrees and covenants to maintain) and the Trustee shall apply, use and withdraw moneys in the Debt Service Fund only for the following purposes:
(1) Interest Account. On each June 1 and December 1, commencing December 1, 2026, the Trustee shall set aside from the Debt Service Fund and deposit in the Interest Account that amount of money which is equal to the aggregate amount of interest becoming Packet Pg. 385 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 13 4909-8297-8690v6/200986-0003
due and payable on all Outstanding 2026 Bonds on such June 1 or December 1, as the case may be.
No deposit need be made in the Interest Account if the amount contained therein is at least equal to the aggregate amount of interest becoming due and payable on all Outstanding 2026 Bonds on such interest payment date.
All money in the Interest Account shall be used and withdrawn by the Trustee solely for the purpose of paying the interest on the 2026 Bonds as it shall become due and payable (including accrued interest on any 2026 Bonds purchased or redeemed prior to maturity). (2) Principal Account. On each June 1, commencing June 1, 20[__], the Trustee shall set aside from the Debt Service Fund and deposit in the Principal Account an amount of money equal to the aggregate principal amount of all Outstanding 2026 Bonds maturing on such June 1.
No deposit need be made in the Principal Account if the amount contained therein is at least equal to the aggregate amount of the principal of all Outstanding 2026 Bonds maturing by their terms on such June 1.
All money in the Principal Account shall be used and withdrawn by the Trustee solely for the purpose of paying the principal of the 2026 Bonds as they shall become due and payable, whether at maturity or redemption.
(3) Surplus Account. The Trustee, on or before June 1 of each year shall deposit in the Surplus Account all money remaining in the Debt Service Fund after the deposits required by the City’s tax covenants and the deposits described in paragraphs (1) and (2) above have been made. On June 16 of each year, the Trustee, if the City is not then in default under the Indenture, shall disburse the money in the Surplus Account to the City.
Rate Covenant
The City covenants under the Indenture to fix, prescribe and collect rates and charges for the services, facilities and electricity of the Electric System during each Fiscal Year which will be at least sufficient to yield:
(a) Adjusted Annual Revenues for such Fiscal Year at least equal to the sum of the following for such Fiscal Year: (i) Maintenance and Operation Costs, (ii) Adjusted Annual Debt Service, and (iii) all other payments required to meet any other obligations of the City which are charges, liens or encumbrances upon or payable from the Electric Revenue Fund, including all amounts owing under Subordinate Obligations; and (b) Adjusted Annual Net Revenues for such Fiscal Year equal to at least 110% of the Adjusted Annual Debt Service for such Fiscal Year.
The City may make adjustments from time to time in such rates and charges and may make such classification thereof as it deems necessary, but covenants not to reduce the rates and charges then in effect unless the Adjusted Annual Revenues and Adjusted Annual Net Revenues from such reduced rates and charges will at all times be sufficient to meet the requirements described above.
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“Adjusted Annual Net Revenues” means for any Fiscal Year or any designated 12-month period in question, the Adjusted Annual Revenues during such Fiscal Year or 12-month period less Maintenance and Operation Costs during such Fiscal Year or 12-month period. “Adjusted Annual Revenues” means for any Fiscal Year or any designated 12-month period in question, the Revenues during such Fiscal Year or 12-month period, less, for purposes of determining compliance with the rate covenant and conditions for the execution of Parity Obligations, any Payment Agreement Receipts taken into account in calculating Annual Debt Service with respect to payment of interest on Parity Obligations, plus, for purposes of determining compliance with the rate covenant only, the amount of Available Reserves on deposit, or which the City has authorized to be deposited, in the Electric Revenue Fund as of the first day of such Fiscal Year or 12-month period.
“Adjusted Annual Debt Service” means for any Fiscal Year or any designated 12-month period in question, the Annual Debt Service for such Fiscal Year or 12-month period minus the sum of the amount of the Annual Debt Service with respect to Outstanding Parity Obligations to be paid during such Fiscal Year or 12-month period, from the proceeds of Parity Obligations or interest earned thereon (other than interest deposited into the Electric Revenue Fund), all as set forth in a Certificate of the City.
“Available Reserves” means as of any date of calculation, the amount of unrestricted funds in the Electric Revenue Fund designated as “Available Reserves” for purposes of the Indenture by the City and then available to pay Maintenance and Operation Costs and/or Annual Debt Service which may include transfers to the Electric Revenue Fund from any fund which is legally available for deposit in the Electric Revenue Fund.
For definitions of certain other terms used herein, see “APPENDIX D – SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE – Definitions.”
No Debt Service Reserve Fund
No debt service reserve fund will be established for the 2026 Bonds. Amounts held in or credited to any other debt service reserve fund established in connection with the Outstanding 2017 Electric System Bonds, 2018 Electric System Bonds, 2025 RJPFA Electric System Bonds or any other Parity Obligations of the City do not secure, and are not available for, the payment of the 2026 Bonds.
Outstanding Electric System Revenue Obligations
Take-or-Pay; Joint Powers Agency Obligations. As described herein, the City has entered into certain power sales contracts for the purchase of energy and certain other agreements for the payment of its share of the costs of certain projects in which it is participating through joint powers agencies, including M-S-R Public Power Agency (“M-S-R PPA”), M-S-R Energy Authority (“M-SR EA”) and the Transmission Agency of Northern California (“TANC”). As of June 2, 2026, the City had outstanding approximately $19.9 million principal amount of obligations related to debt of the joint powers agencies in which it participates (exclusive of obligations relating to debt of M-S-R EA which debt is nonrecourse to the City). See “THE ELECTRIC SYSTEM – Power Supply Resources – Joint Powers Agency Resources” and “– Indebtedness.” The City’s obligations under such contracts constitute a portion of the Maintenance and Operation Costs of the Electric System, payable Packet Pg. 387 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 15 4909-8297-8690v6/200986-0003
from Revenues of the Electric System prior to the 2026 Bonds and other Parity Obligations. The City may incur additional obligations pursuant to its agreements with such joint power agencies in which it participates or enter into other contacts or leases for the purchase of facilities, properties, structures or works or electric output, capacity or other electrical services for the Electric System which are Maintenance and Operation Costs of the Electric System, payable from Revenues of the Electric System prior to the 2026 Bonds and other Parity Obligations. See also “– Rate Covenant” above.
Outstanding Parity Obligations. As of June 2, 2026, the City had outstanding Parity Obligations in the aggregate principal amount of $127,710,000, comprised of (i) the 2017 Electric System Bonds outstanding in the principal amount of $22,945,000, (ii) the 2018 Electric System Bonds outstanding in the principal amount of $14,970,000 (iii) installment sale payments related to the 2015 RJPFA Electric System Bonds outstanding in the principal amount of $23,750,000 (all of which is being refunded by the 2026 Bonds) and (iv) installment sale payments related to the 2025 RJPFA Electric System Bonds outstanding in the principal amount of $66,045,000.
The 2017 Electric System Bonds were issued pursuant to an Indenture, dated as of April 1, 2017 (the “2017 Indenture”), by and between the City and U.S. Bank Trust Company, National Association, as successor trustee. The 2018 Electric System Bonds were issued pursuant to an Indenture, dated as of March 1, 2018 (the “2018 Indenture”), by and between the City and U.S.
Bank Trust Company, National Association, as successor trustee. The 2015 RJPFA Electric System Bonds were issued pursuant to a trust agreement, dated as of December 1, 2015, by and between the Authority and U.S. Bank Trust Company, National Association, as successor trustee. The 2015 RJPFA Electric System Bonds are payable primarily from certain installment sale payments required to be made by the City to the Authority under the terms of the 2015A Installment Sale Agreement, by and between the City and the Authority (all of which is being refunded by the 2026 Bonds, See “PLAN OF REFUNDING”). The 2025 RJPFA Electric System Bonds were issued pursuant to a trust agreement, dated as of April 1, 2025, by and between the Authority and U.S. Bank Trust Company, National Association, as trustee. The 2025 RJPFA Electric System Bonds are payable primarily from certain installment sale payments required to be made by the City to the Authority under the terms of a 2025 Installment Sale Agreement, dated as of April 1, 2025 (the “2025 Installment Sale Agreement”), by and between the City and the Authority.
The 2026 Bonds are payable from Net Revenues of the City’s Electric System on a parity with the payment from such Net Revenues of the 2017 Electric System Bonds, the 2018 Electric System Bonds, and the installment sale payments payable pursuant to the 2025 Installment Sale Agreement relating to the 2025 RJPFA Electric System Bonds.
The City may hereafter incur additional Parity Obligations which are payable from Net Revenues on a parity with the outstanding Parity Obligations in accordance with the terms of the Indenture as described below.
Outstanding Subordinate Obligations. In May 2023, the City and the Authority entered into the Revolving Credit Agreement with the Credit Bank. Under the Revolving Credit Agreement, the Credit Bank has agreed to advance funds to the Authority, from time to time, in an amount up to $25.0 million, for the benefit of the City’s Electric System. The term of the Revolving Credit Agreement extends to November 1, 2028, unless extended or earlier terminated pursuant to its terms.
Borrowings under the Revolving Credit Agreement are payable from, and secured by, installment sale payments required to be made by the City to the Authority under the Subordinate Installment Sale Agreement, by and between the City and the Authority. The installment sale payments required Packet Pg. 388 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 16 4909-8297-8690v6/200986-0003
to be made by the City under the Subordinate Installment Sale Agreement constitute Subordinate Obligations, payable from Net Revenues of the Electric System of the City subject and subordinate to the City’s obligation to pay the 2026 Bonds and the other Parity Obligations. As of June 2, 2026, there were no borrowings by the City outstanding under such Revolving Credit Agreement. See also “THE ELECTRIC SYSTEM – Indebtedness” for additional information regarding the terms of the Revolving Credit Agreement, including certain circumstances and the terms under which the installment sale payment obligations of the City under the Subordinate Installment Sale Agreement relating thereto may be accelerated or otherwise become due prior to maturity. The City may incur additional Subordinate Obligations in the future in accordance with the terms of the Indenture as described below.
Additional Electric System Revenue Obligations
Additional Take-or-Pay and Other Contracts. The City may incur additional obligations pursuant to its agreements with such joint power agencies in which it now, or in the future may, participate or enter into other contacts or leases for the purchase of facilities, properties, structures or works or electric output, capacity or other electrical services for the Electric System which are Maintenance and Operation Costs of the Electric System, payable from Revenues of the Electric System prior to the 2026 Bonds and other Parity Obligations. See also “– Rate Covenant” above.
Additional Parity Obligations. The City will covenant pursuant to the Indenture that it will not incur additional obligations payable from and secured by a lien on Net Revenues of the Electric System or moneys in the Electric Revenue Fund prior to the lien and charge securing the 2026 Bonds. In addition to the City’s obligation to pay the Parity Obligations to be outstanding upon the delivery of the 2026 Bonds, the City may at any time execute and deliver any additional Parity Obligations, the payment of which is payable from and secured by a lien and charge on the Net Revenues and moneys in the Electric Revenue Fund on a parity with the charge and lien on the Net Revenues and moneys in the Electric Revenue Fund securing the 2026 Bonds and such outstanding Parity Obligations, subject to certain conditions, including among others, that:
(a) either –
(1) during any 12 consecutive calendar months out of the immediately preceding 18 calendar month period, the Adjusted Annual Net Revenues were at least equal to 110% of the Maximum Annual Debt Service for all Outstanding 2026 Bonds and all Outstanding Parity Obligations plus the Parity Obligation proposed to be executed; or
(2) as evidenced by a Certificate of the City, the projected Adjusted Annual Net Revenues during the succeeding first complete Fiscal Year following issuance of such Parity Obligation in which interest is not capitalized in whole or in part from the proceeds of Parity Obligations, is at least equal to 110% of the Maximum Annual Debt Service for all Outstanding 2026 Bonds and all Outstanding Parity Obligations plus the Parity Obligation proposed to be executed; and (b) no Event of Default (or any event which would become an Event of Default once all notice or grace periods have passed) exists unless such Event of Default or default shall be cured upon such issuance.
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Notwithstanding the foregoing, the provisions described in paragraph (a) above shall not limit the ability of the City to execute any Parity Obligations at any time to refund any Outstanding Parity Obligations which results in a present value savings to the City, inclusive of all costs of such refunding.
Subordinate Obligations. The Indenture provides that the City may incur Subordinate Obligations without meeting the tests set forth above.
Investment of Funds
All funds held under the Indenture are required to be invested in certain Permitted Investments as provided under the Indenture. See “APPENDIX D – SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE – Definitions” for the definition of Permitted Investments.
Funds held by the City are invested by the City in accordance with the City’s Investment Policy as authorized by Section 53600 et seq. of the Government Code of the State of California.
Allowable investments under the Investment Policy are those authorized by California Government Code Sections 53601 and 53630. See “THE ELECTRIC SYSTEM – City Investment Policy.” All investments, including the Permitted Investments and those authorized by law from time to time for investments by public agencies, contain a certain degree of risk. Such risks include, but are not limited to, a lower rate of return than expected and loss or delayed receipt of principal. The occurrence of these events with respect to amounts held under the Indenture, or other amounts held by the City, could have a material adverse effect on the City’s finances.
Limitations on Remedies
The rights of the owners of the 2026 Bonds are subject to the limitations on legal remedies against public agencies in the State. Additionally, enforceability of the rights and remedies of the owners of the 2026 Bonds, and the obligations incurred by the City, may become subject to the following: the Federal Bankruptcy Code and applicable bankruptcy, insolvency, reorganization, moratorium, or similar laws relating to or affecting the enforcement of creditors’ rights generally, now or hereafter in effect; equity principles which may limit the specific enforcement under State law of certain remedies; the exercise by the United States of America of the powers delegated to it by the Constitution; and the reasonable and necessary exercise, in certain exceptional situations, of the police powers inherent in the sovereignty of the State and its governmental bodies in the interest of serving a significant and legitimate public purpose. Bankruptcy proceedings, or the exercise of powers by the federal or State government, if initiated, could subject the owners of the 2026 Bonds to judicial discretion and interpretation of their rights in bankruptcy or otherwise, and consequently may entail risks of delay, limitation, or modification of their rights.
THE ELECTRIC SYSTEM
General
The City is a general law city of the State of California. As a general law city, the City has the power to furnish electric utility service to its inhabitants. In connection therewith, the City has the powers of eminent domain, to contract, to construct works, to fix rates and charges for commodities or services furnished and to incur indebtedness. Specifically, the City Council is authorized by the Redding Municipal Code to establish electric utility rates for all electric utility subscribers, and any rate changes are not subject to regulatory agency review.
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The City provides electric utility service through the Electric Utility Department. The legal responsibilities and powers of the Electric Utility Department, including the establishment of rates and charges, are exercised through the five-member City Council. The members of the City Council are elected City-wide for staggered four-year terms. The Electric Utility Department is under the direction of the Director of the Electric Utility Department who is appointed by the City Manager.
To provide electric service within its service area (which is coterminous with the City’s corporate city boundaries), the City owns and operates an Electric System that includes generation, transmission and distribution facilities. The City also purchases power and transmission service from others. In addition, the City provides normal city services to its inhabitants such as police and fire protection and water and sewer service.
Since 1921, the City has provided electric service within its boundaries. For the Fiscal Year ended June 30, 2025, the City served approximately 45,591 customer accounts, had total sales of approximately 770.5 million kWh and a peak demand of 240.9 MW.
Management
The City’s electric utility operations are carried out under the direction of the Director of the Electric Utility Department and in accordance with the City Council’s directives and policies.
Nick Zettel is the Electric Utility Director for the City of Redding Electric Utility. Mr. Zettel holds a Bachelor of Science degree in Financial Management and has worked at the Electric Utility Department for over 20 years holding various positions in resource planning, energy trading, market operations, and leadership team development. He is a member of the Central Valley Project O&M Governance Board, the Central Valley Project Corporation Board of Directors, and Commissioner of the Balancing Authority of Northern California, the Transmission Agency of Northern California, and the M-S-R Public Power Agency and M-S-R Energy Authority.
Power Supply Resources
The following table sets forth information concerning the Electric Utility Department’s power supply resources and the percent of total energy supplied by each during the Fiscal Year ended June 30, 2025.
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CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
POWER SUPPLY RESOURCES
(For the Fiscal Year Ended June 30, 2025)
Source
Capacity
Available
(MW)(1)
Actual Energy
(GWh)
Percent of
Total Energy(2)
Purchased Power:
Western Base Resource 128.5 279.3 25.6%
M-S-R PPA/Big Horn I Wind Project 23.0 165.9 15.2
Short-Term Purchases(3) N/A 417.5 38.3
Total Purchased Power(1) 151.5 862.7 79.1
Generation Facilities:
Redding Power Plant(4) 183.1 221.4 20.3
Whiskeytown 3.5 7.2 0.7
Total Generated Power 186.6 228.6 20.9
Total (Generated and Purchased)(2) 338.1 1,091.3 100.0
Total Energy Sold and
Exchanged at Wholesale N/A 307.9 28.2
System Requirement for Retail N/A 783.4 71.8
(1) Capacities listed may not be available at all times and do not necessarily represent values used for resource planning.
(2) Totals may not add due to rounding.
(3) Includes power purchases for resale. See “–Wholesale Energy Trading” below. (4) Capacity listed is nameplate capacity (EIA860 defined) for Redding Power Plant.
Source: City of Redding.
The City’s Redding Power Plant serves as its primary local generation resource (although the City substitutes market purchases when economical to do so). The Redding Power Plant has a total nameplate capacity of 183.1 MW, or approximately 1,300 GWh of available energy per year. The plant was expanded to its current capacity in 2011 with the addition of Unit 6, a natural gas-fired combined cycle generator which added 42.5 MW of capacity to the plant. This addition was designed, in part, to offset an expected decrease in energy to be received by the City as a result of the expiration of certain previously existing power supply arrangements. See “– Joint Powers Agency Resources-Purchased Power, Generation and Transmission – M-S-R PPA – San Juan Retained Obligations” below. The Redding Power Plant, together with the City’s other existing power supply resources and additional renewable resources anticipated to be acquired by the City to meet future regulatory requirements, are currently expected by the City to be sufficient to supply the City’s projected energy needs through the foreseeable future.
Each of the City’s power supply resources are briefly described below.
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Generating Facilities
Redding Power Plant. The Redding Power Plant is located on a site owned by the City within the city limits of Redding. The Redding Power Plant presently consists of the following components: (i) a two-on-one combined cycle power generating plant that uses two Siemens SGT-800 gas turbines, one with a 40 MW nameplate capacity and one with a 42.5 MW nameplate capacity, operating in combined cycle with a 26.8 MW GE steam turbine, and (ii) three GE Frame 5 simple cycle combustion turbines, with a combined nameplate capacity of 73.8 MW, for a total station nameplate capacity of 183.1 MW.
The initial steam unit at the Redding Power Plant was acquired by the City in August 1991 and was converted from biomass fuel to natural gas in 1994. The three simple cycle combustion turbines were added to the Redding Power Plant site in October 1996. The first SGT-800 gas turbine, Unit No. 5, was placed into commercial operation in June 2002. Unit No. 6, the second SGT-800 gas turbine with a heat recovery steam generator, was placed into commercial operation in August 2011. See also “–Fuel Supply” below.
Whiskeytown Project. The City owns and operates a 3.5 MW hydroelectric generating plant located at the United States Bureau of Reclamation (the “U.S. Bureau of Reclamation”) Whiskeytown Dam near Redding, California. This project, completed in 1986, has produced average annual energy in the amount of approximately 25 GWh. In some years, temporarily high flow releases have been captured by the flexibility of the dual runners installed in the Whiskeytown unit and additional energy has been generated. The City estimates that under minimum flow releases, this hydroelectric generation facility will produce approximately 10 GWh per year. The City estimates that this hydroelectric generation facility will produce approximately 23 GWh in Fiscal Year 2025-26. The City has received full California Energy Commission (“CEC”) certification for the Whiskeytown hydroelectric facility as a California Renewable Portfolio Standard (“RPS”) “Eligible” renewable resource. The Whiskeytown hydroelectric facility has been registered with the Western Renewable Energy Generation Information System (“WREGIS”), and the associated renewable energy credits (“RECs”) will either be retained by the City electric utility for RPS compliance purposes or utilized for wholesale sales.
Joint Powers Agency Resources – Purchased Power, Generation and Transmission TANC California-Oregon Transmission Project. The City, together with fourteen other northern California cities, utility districts and one rural electric cooperative, is a member or associate member of a California joint powers agency known as the Transmission Agency of Northern California (referred to herein as TANC). TANC, together with Western Area Power Administration (“Western”) and PG&E (collectively, the “COTP Participants”), own the California–Oregon Transmission Project (the “COTP”), a 339-mile long, 1,700 MW (as most recently re-rated), 500 kV transmission project between southern Oregon and central California. The COTP was placed in service on March 24, 1993, at an original cost of approximately $430 million.
To utilize the full transfer capability of the COTP on a firm basis and maximize the benefits of the line, the COTP is operated on a coordinated basis with the Pacific AC Intertie (the “Intertie”), a twoline system which, like the COTP, connects California utilities with those in the Pacific Northwest. The Intertie lines are owned by PG&E, PacifiCorp and Western and are operated by the California Independent System Operator Corporation (the “CAISO”). Rate schedules are on file with the Federal Energy Regulatory Commission (“FERC”) to accomplish this coordination. The three-line system comprised of the COTP and the Intertie is collectively referred to as the California-Oregon Intertie.
Pursuant to Project Agreement No. 3 for the COTP (the “TANC Agreement”), TANC has agreed to provide to the City and 12 other members of TANC (the “TANC Member-Participants”) a participation percentage of TANC’s entitlement (currently approximately 1,505.6 MW) of COTP transfer capability. In Packet Pg. 393 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 21 4909-8297-8690v6/200986-0003
return, each TANC Member-Participant has severally agreed to pay TANC a corresponding percentage of TANC’s share of the COTP construction costs, including debt service on TANC’s revenue bonds and other obligations issued by TANC to finance its ownership share of the COTP. A TANC MemberParticipant’s obligations to make payments to TANC are not dependent upon the operation of the COTP and are not subject to reduction. Upon an unremedied default by one TANC Member in making a payment required under the TANC Agreement, the non-defaulting TANC Member-Participants are required to increase pro-rata their participation percentage by the amount of the defaulting TANC Member-Participant’s entitlement share, provided that no such increase can result in a greater than 25% increase in the participation percentage of a non-defaulting TANC Member-Participant. See “– Indebtedness” below.
The City gains access to its COTP entitlements (representing approximately 148 MW of COTP scheduling rights as more fully described below) through a long-term transmission service contract with Western. See “– Interconnections, Transmission and Distribution.” The City is currently using a portion of its COTP transfer capability to provide transmission of renewable wind capacity and energy purchased through M-S-R PPA. See “M-S-R PPA Purchased Power-Big Horn I Wind Energy Project” below. The remaining transfer capability is used to make spot market purchases of firm and non-firm energy and as reliability backup for the City’s firm power purchases and sales commitments.
TANC’s current ownership interest in the COTP includes certain COTP transmission assets (representing an approximately 121 MW entitlement) purchased by TANC in April 2008 from Vernon Light & Power of the City of Vernon, California (“Vernon”), one of the original owners of the COTP.
The City, as well as six other TANC Members, participated in the acquisition from Vernon and share in the increase in COTP entitlement rights and are responsible for the associated cost obligation for this TANC interest. In addition, effective as of January 1, 2025, TANC accepted the assignment and transfer from the City of a 1.7496% share (approximately 25 MW) ownership interest in the COTP purchased by the City in April 2005 from the City of Shasta Lake, another original owner of the COTP. The City will retain its rights to utilize such COTP entitlement previously owned by the City and transferred to TANC, and the City is responsible for the associated cost obligation. Also effective as of January 1, 2025, TANC accepted the assignment and transfer of certain interests in the COTP (representing approximately 2 MW) acquired by the City of Roseville (“Roseville”) and the Turlock Irrigation District (“TID”) from the San Juan Water District and Carmichael Water District, as original owners of the COTP. Roseville and TID enjoy the COTP entitlement rights represented by these COTP interests and are responsible for the associated cost obligations.
TANC financed its interest in the COTP through the issuance of California-Oregon Transmission Project revenue bonds, of which approximately $152.1 million principal amount was outstanding as of January 1, 2026. In November 2021, TANC approved a 20-year capital replacement plan for the COTP.
In August 2024, TANC approved the execution and delivery of a Credit Agreement with JPMorgan Chase Bank, National Association (the “TANC Credit Agreement”), establishing a line of credit pursuant to which TANC may borrow, pay down, refund and re-borrow, through the issuance and sale from time to time of short-term variable rate notes (“TANC short-term notes”), an aggregate amount outstanding at any time of up to $120,000,000 for the purpose of financing improvements to the COTP on an interim basis. TANC executed the TANC Credit Agreement in September 2024. On August 1, 2025, TANC amended the TANC Credit Agreement to extend the maturity date from September 3, 2025, to September 3, 2027. As of June 2, 2026, $91.7 million aggregate principal amount of TANC short-term notes were outstanding under the TANC Credit Agreement. See “– Indebtedness – Joint Powers Agency Obligations.”
Pursuant to the TANC Agreement (and the effect of the subsequently acquired interests described above), the City is obligated to pay 10.04% of TANC’s COTP operating and maintenance expenses and Packet Pg. 394 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 22 4909-8297-8690v6/200986-0003
approximately 8.4% of TANC’s debt service on its outstanding bonds and notes. The City will be obligated to pay approximately 10.04% of TANC’s debt service on future TANC indebtedness incurred in connection with the currently ongoing 20-year COTP capital replacement plan (including the anticipated take-out financing of the outstanding notes issued). See “– Indebtedness – Take-or-Pay; Joint Powers Agency Obligations.” The City is entitled to 10.04% of TANC’s share of COTP transfer capability (approximately 148 MW net of life-of-the asset third-party layoffs by TANC) on an unconditional take-or-pay basis. The City’ share of annual operating and maintenance expenses and debt service payable to TANC pursuant to the TANC Agreement is estimated to be approximately $6.6 million per year. The City’s payments to TANC, including payments for debt service on TANC’s revenue bonds and other debt obligations, constitute Maintenance and Operation Costs of the City’s Electric System.
The COTP is operated within the Balancing Authority of Northern California (“BANC”) balancing authority area. A balancing authority performs a balancing function in which customer usage and resources are matched on a moment-by-moment basis. In addition, a balancing authority operates the transmission system, monitoring power lines to ensure they are operated within the reliable limits of the system in addition to coordinating the operation with neighboring balancing authorities. The City is a member of BANC. See “–Interconnections, Local Transmission and Distribution Facilities” below. Under BANC, the City enjoys the benefits of direct scheduling energy transactions over the COTP within the balancing authority area, free of the CAISO tariff, charges, congestion and encumbrances.
As the 340-mile COTP transmission line runs from Klamath County in Southern Oregon to the Tesla Substation located south of the City of Tracy in San Joaquin County, in central California, approximately 34% of the transmission line runs through the “elevated” Tier 2 fire risk zone and 1% runs through the “extreme” Tier 3 fire risk zone as identified on the CPUC’s Fire-Threat Map. TANC employs a fire risk management plan to mitigate its wildfire risk exposure that includes semi-annual aerial inspections; a series of annual ground inspections; a rigorous vegetation management program; as well as limiting crops and vegetation height in orchard areas. The COTP is constructed entirely of steel lattice towers or single pole steel structures which includes a 200 foot right-of-way for the majority of the COTP that is kept clear of trees and large vegetation. TANC has submitted its wildfire mitigation plan for the COTP to the California Wildfire Safety Advisory Board (the “Wildfire Advisory Board”) as required by California Senate Bill 901 (“SB 901”). See “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY – State Legislation and Regulatory Proceedings – Legislation Relating to Wildfires; Related Risks.”
Tesla-Midway Transmission Service. The southern physical terminus of the COTP is near PG&E’s Tesla Substation near Tracy, California. TANC has arranged for PG&E to provide TANC and certain TANC Members with 300 MW of firm, bi-directional transmission capacity on its transmission system between PG&E’s Tesla Substation and the Midway Substation in Buttonwillow, California (the “Tesla-Midway Service”) under a long-term agreement known as the South of Tesla Principles. The City’s share of Tesla-Midway Service is 31 MW. This transmission service enhances the value of the COTP to TANC and the TANC Member-Participants by increasing opportunities for energy purchases, sales and other utility arrangements. The City has utilized its full allocation of Tesla-Midway transmission service for firm and non-firm power transactions.
M-S-R PPA Purchased Power–Big Horn I Wind Energy Project. The City, along with the Modesto Irrigation District (“Modesto”) and the City of Santa Clara (“Santa Clara”), is a member of a California joint powers agency known as the M-S-R Public Power Agency (referred to herein as M-S-R PPA). In 2005, M-S-R PPA entered into a series of power purchase agreements with Avangrid Renewables, Inc. (originally PPM Energy, Inc. and formerly Iberdrola Renewables, Inc.) (“Avangrid”), certain of which agreements have been assigned to Avangrid’s subsidiary, Big Horn I, LLC, for the purchase of energy from the Big Horn I wind energy project (the “Big Horn I Project”) located near the Packet Pg. 395 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 23 4909-8297-8690v6/200986-0003
town of Bickleton, in Klickitat County, Washington. The 199.5 MW project consists of 133 1.5 MW GE wind turbines. The City participates in the purchase of a 35% share of the output from the Big Horn I Project through M-S-R PPA. The City’s share equates to approximately a 70 MW share of the project output. The cost for the City’s 70 MW output share equates to a cost roughly comparable to combined cycle gas–fired generation. Power deliveries commenced on October 1, 2006, and will continue through September 30, 2026. Through an amendment of the original agreements M-S-R PPA has an obligation to continue to take the same output through September 30, 2031, or if the Big Horn I Project is repowered, M-S-R PPA will have a right of first offer to negotiate a long-term power purchase for such repowered project. Recently, M-S-R PPA members were notified that the current Big Horn PPA provider intends to exercise an option that would terminate the agreement earlier than 2031. M-S-R PPA members (including the City) are evaluating several options to either continue with Big Horn or secure a replacement resource. The project interconnects with the high voltage transmission grid through an 11-mile transmission line at the Spring Creek Substation of Bonneville Power Administration (“BPA”). Through the shaping and firming agreement between M-S-R PPA and Avangrid, Avangrid receives Big Horn I Wind energy, as generated, and delivers such energy to M-S-R PPA at the California-Oregon border pursuant to firm pre-established delivery schedules. The City uses a portion of its COTP transfer capability to provide for transmission of the output from the Big Horn I Project from the CaliforniaOregon border to the City.
The Big Horn I Project is operated within the Avangrid balancing authority (which began operating in mid-2018) and delivered through the BPA balancing authority area. On October 1, 2009, BPA began imposing a wind integration charge for the purpose of recovering its costs to provide withinhour generation balancing services for wind generators. Pursuant to a series of amendments of the power purchase agreements between M-S-R PPA and Avangrid effective September 18, 2019, M-S-R PPA agreed to pay to Avangrid, following the effective date of operation of the Avangrid balancing authority on July 31, 2018, in lieu of responsibility for payment of any wind integration charges to BPA, a wind integration charge of $1.10/kW month through December 31, 2018 and $1.01/kW month thereafter.
Through a collaborative effort between Avangrid and M-S-R PPA, the Big Horn I Project has obtained California RPS certification as an “Eligible” renewable resource by the CEC. The Big Horn I Project has been registered with the WREGIS by Avangrid with BPA acting as the Qualified Reporting Entity. The RECs are transferred from Avangrid, the originator, to M-S-R PPA and finally to the members of M-S-R PPA, for either retirement or wholesale sales by such members.
BPA establishes rates to be charged for power and transmission services in biennial formal evidentiary hearing processes. Changes in BPA rates indirectly affect the Big Horn I Project costs through formulaic adjustments to prices paid to Avangrid.
M-S-R PPA–San Juan Retained Obligations. The City’s resources acquired through M-S-R PPA previously included an entitlement to a portion of the output of M-S-R PPA’s prior ownership interest in Unit No. 4 of the San Juan Generating Station (hereinafter, the “M-S-R PPA San Juan Unit No. 4 Interest”), a coal-fired steam electric generating unit located in San Juan County, New Mexico, which was constructed and operated by the Public Service Company of New Mexico (“PNM”). M-S-R PPA divested its M-S-R PPA San Juan Unit No. 4 Interest on December 31, 2017, although it retains certain liabilities for a share of the costs of environmental remediation obligations and plant decommissioning and mine reclamation, as described below. The final operating unit of the San Juan Project, Unit No. 4, permanently ceased operations on September 29, 2022.
M-S-R PPA purchased its 28.8% (approximately 146 MW) M-S-R PPA San Juan Unit No. 4 Interest on December 31, 1983 and began dispatching power from such interest in May 1995. M-S-R PPA financed the acquisition of its M-S-R PPA San Juan Unit No. 4 Interest, and certain costs of related transmission arrangements, through the issuance of its San Juan Project revenue bonds, all of which were Packet Pg. 396 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 24 4909-8297-8690v6/200986-0003
retired as of July 1, 2022. The City purchased from M-S-R PPA, on a take-or-pay basis, a 15% entitlement share in the M-S-R PPA San Juan Unit No. 4 Interest pursuant to a power sales agreement (the “M-S-R PPA Agreement”), among M-S-R PPA and its members.
The divestiture of M-S-R PPA’s interests in San Juan Unit No. 4 (referenced above) was completed pursuant to a number of agreements (the “San Juan Restructuring Agreements”) between and among the prior San Juan Generation Station owners (the “San Juan Participants”), which provided for the interests of M-S-R PPA and certain other San Juan Participants (the “Divested San Juan Participants”) in the San Juan Generation Station to be transferred to the remaining San Juan Participants effective December 31, 2017. In addition to the ownership divesture, the San Juan Restructuring Agreements provide for, among other things, the allocation of ongoing responsibility for decommissioning costs, mine reclamation costs and any environmental remediation obligations among the Divested San Juan Participants and the remaining San Juan Participants, and the establishment and funding of mine reclamation and plant decommissioning trust funds.
Pursuant to the San Juan Restructuring Agreements, M-S-R PPA and the other Divested San Juan Participants retain certain liabilities for a share of the costs of San Juan Generation Station decommissioning and pre-exit date mine reclamation costs. Under the San Juan Restructuring Agreements, M-S-R PPA was required to maintain a balance of approximately $10.5 million in the mine reclamation trust funds as of December 31, 2025 to fund its currently expected share of ongoing and final reclamation costs, which requirement was met by a year-end balance at such date of approximately $10.5 million. In addition, under the San Juan Restructuring Agreements, M-S-R PPA was required to maintain a balance of approximately $0.80 million in the decommissioning trust fund as of December 31, 2025 to fund its currently expected share of the initial work for known asset removal and remediation activities in connection with demolition of the San Juan Generation Station, which requirement was met by a year-end balance at such date of approximately $0.80 million. As of December 31, 2025, M-S-R PPA’s future liabilities for mine reclamation and plant demolition costs are approximately $10 million and 1.5 million, respectively, as documented in the 2026 Ten-Year Resource and Legacy Liability Cost Forecast accepted by the M-S-R PPA Commission on February 18, 2026. However, M-S-R PPA’s final total proportionate share of San Juan Generation Station decommissioning and mine reclamation costs cannot yet be determined and will depend on a number of factors, including, among other things, actual costs for the demolition and site remediation work. Additional deposits to the trust funds may be required in the future if trust earnings are below expectations or if determined necessary by future decommissioning and reclamation costs study updates.
Pursuant to the M-S-R PPA Agreement, the City is unconditionally obligated thereunder to pay its entitlement share (35%) of all of M-S-R PPA’s costs associated with the M-S-R PPA San Juan Unit No. 4 Interest, including any remaining liabilities for environmental remediation obligations, decommissioning and mine reclamation of the plant associated with the M-S-R PPA San Juan Unit No. 4 Interest. The City’s payments to M-S-R PPA under the M-S-R PPA Agreement constitute Maintenance and Operation Costs of the City’s Electric System. The City’s obligations to make payments under the M-S-R PPA Agreement are not dependent upon the continued ownership or operation of the San Juan Unit No. 4 and are not subject to reduction. Pursuant to the M-S-R PPA Agreement, upon failure of any M-S-R PPA member to make any payment thereunder which failure constitutes a default under the M-S-R PPA Agreement, the participation percentage of each non-defaulting member automatically will be increased for the remaining term of the M-S-R PPA Agreement in proportion to its participation percentage; provided, however, that the sum of such increase for any non-defaulting member shall not exceed 25% of its original participation percentage.
In light of the divesture of its active ownership interest in San Juan Unit No. 4, the majority of M-S-R PPA activities are currently related to renewables (including the Big Horn I Project described Packet Pg. 397 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 25 4909-8297-8690v6/200986-0003
above). Coordinating, regulatory, and compliance services costs of M-S-R PPA are shared among the M-S-R PPA members as follows: the City – 20%; Modesto – 40%; and Santa Clara – 40%. Renewable administrative services, electric product, delivery and environmental attribute rights, benefits and costs are shared in accordance with contracted participation ratios described above.
NCPA. The City is a member of the Northern California Power Agency (“NCPA”). NCPA owns certain electric generating projects. The City is not currently a participant in any of the NCPA projects.
As a member of NCPA, the City participates in NCPA’s state and federal legislative and regulatory matters.
Purchased Power
Western. The City receives a significant portion of its supply of power from the Central Valley Project (the “CVP”) pursuant to a contract with Western. The CVP, for which Western serves as marketing agency, is a series of federal hydroelectric facilities in Northern California operated by the U.S.
Bureau of Reclamation. Delivery of purchased power from Western is made by Western over the CVP transmission system at the City’s two interconnection points with Western: (1) the Keswick Dam Switchyard, a Western facility located approximately 0.5 miles from the City, and (2) the City’s Airport Substation, which is jointly owned by Western and the City, and located in the southeastern part of the City. The rates and terms of this service is in accordance with Western’s then-current rate schedule and Open Access Transmission Tariff (“OATT”). Power is transmitted to the City’s distribution substations over the City’s 115 kV transmission lines.
The City previously purchased low-cost hydroelectricity from the CVP under a 20-year agreement with Western which began on January 1, 2005 and continued through 2024 (and which agreement replaced a prior agreement which expired December 31, 2004). Under such agreement, the City initially received a 7.7% “slice of the system” base resource allocation from Western. As of January 1, 2015, Western revised its allocation percentages, and the City’s allocation increased to 8.159% for the then remaining term. The power marketed by Western to the City is provided on a take-or-pay basis wherein Western’s annual costs are allocated to all CVP preference customers based on their CVP participation percentage. Western then allocates the annual take-or-pay charges to the CVP preference customers based on a monthly percentage that is designed to reflect the anticipated seasonal energy deliveries. The City is obligated to pay its preference customer share of the costs associated with operating the CVP facilities.
In January 2021, the City executed a 30-year agreement with Western for the continued purchase of hydroelectricity from the CVP, the term of which agreement began on January 1, 2025 and will continue through December 31, 2054 (unless earlier terminated). The agreement is similar to the City’s prior contract with Western, but the City’s base resource allocation decreased to 7.99604% beginning in 2025. In addition, in 2040, the allocation of CVP to Western customers (including the City) will be reduced by 1% to allow for new Western customers. Under the new agreement, the City may reduce its CVP quantity or terminate the agreement when a new rate schedule is adopted or extended (which will occur at least every five years).
The City’s contract with Western includes power from numerous hydroelectric plants around the Sierra Nevada region, some of which qualify as a California RPS “Eligible” renewable resource. The City participates in Western’s Sierra Nevada region program (the “small hydro program”) to receive the RECs from the qualifying hydroelectric projects. RECs from these qualifying hydroelectric facilities (under 30 MW) account for approximately 3.0% of the City’s base resource allocation from Western.
Packet Pg. 398 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 26 4909-8297-8690v6/200986-0003
The table below shows the deliveries and wholesale power rates charged by Western for Fiscal Years 2021-22 through 2024-25 and the projected deliveries and power rates to be charged by Western for Fiscal Year 2025-26. Energy made available for delivery to the City under its agreement with Western is subject to the annual hydrology of the CVP, and can vary significantly from year to year. Deliveries in Fiscal Years 2021-22 through 2022-23 reflect the then ongoing drought conditions in California. For planning purposes, Western provides estimates of projected deliveries based upon Western’s assessment of current and expected hydrologic conditions. The projected deliveries for Fiscal Year 2025-26 are based upon amounts received to November 2025 and Western’s estimates as of December 2025, and will be subject to hydrologic conditions for the remainder of the Fiscal Year.
Western Area Power Administration
Wholesale Power Rates and Deliveries
(Historical and Projected – Fiscal Years 2021-22 through 2025-26) Fiscal Year
Energy
(GWh)
Price
$/MWh
2021-22 122,059 $47.10
2022-23 128,052 40.09
2023-24 285,228 14.44
2024-25 232,022 18.21
2025-26(1) 243,161 17.37
__________________
(1) Projected Fiscal Year 2025-26 power rates and deliveries based on actual amounts to November 2025 and Western’s estimates as of December 2025.
Source: City of Redding.
Hydrology in California can be highly variable from year to year. In an average water year, approximately 30% of the City’s power supply resources are derived from hydroelectric sources, including both the Whiskeytown Project and power purchased from Western. In the event of reduced hydroelectric generation, it is necessary for the City to generate additional energy or to purchase additional energy on the wholesale market to meet its retail sales and load obligations, both of which incur additional costs.
Renewable Resources
Current Energy Mix. The City has a diversified renewable portfolio that includes wind power purchase agreements and hydroelectric resources. As described above, these currently include the City’s purchase through M-S-R PPA of a portion of the output of the Big Horn I Project (wind energy), as well as the City’s participation in Western’s small hydro program. The City also owns and operates its small hydroelectric generating plant at the base of Whiskeytown Dam. Additionally, the City has also entered into a long-term and short-term renewable energy power purchase agreements to purchase eligible renewable energy from various generators in various quantities.
Packet Pg. 399 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 27 4909-8297-8690v6/200986-0003
The table below set forth the City’s estimated mix of power resources used to generate the electricity sold to customers for calendar year 2024.
CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
GENERATION MIX PERCENTAGES
(2024)
(1)
Energy Resource Type
Redding
Power Mix
Percentage(1)
Eligible Renewable(2) 27%
Biomass and Biowaste 0
Geothermal 0
Eligible Hydroelectric 3
Solar 0
Wind 23
Coal 0
Large Hydroelectric 42
Natural Gas 30
Nuclear 1
Other 0
Unspecified Sources of Power(3) 0
Total 100%
(1) Based on the City’s calendar year 2024 (most recent) Annual Power Content label submission to the CEC. (2) The eligible renewable percentage in table above does not reflect RPS compliance, which is determined using a different methodology.
(3) Unspecified power is electricity that has been purchased through open market transactions and is not traceable to a specific generation source.
Source: City of Redding.
City Renewable Portfolio Standard. Over the last two decades, the City has taken numerous steps towards satisfying the RPS targets set forth in State legislation, and has pursued cost-effective contracts and ownership opportunities for renewable resources. In response to the adoption of California Senate Bill 1078 in 2002, the City first formally adopted a Renewables Portfolio Standard (RPS) in 2003 which stated that the City would meet or exceed a standard of 20% of the City’s annual energy needs to be provided by state qualified renewable resources by 2017. Following the development by the California Air Resources Board (“CARB”) of a Renewable Energy Standard, the City updated its RPS policy in 2011 to include a 33% by 2020 goal. In accordance with the California Renewable Energy Resources Act, enacted in 2011 as SBX1-2 (“SBX1-2”), the City was required to develop and implement a renewable energy resources plan which provided that a specified average of the Electric System’s retail sales must be procured from eligible renewable energy resources during specified compliance periods through 2020.
The City was “deemed in compliance” with the RPS procurement requirements for Compliance Period 1 (2011-2013) by the CEC, satisfying its RPS obligation with an optional compliance measure. The City satisfied the RPS target for Compliance Period 2 (from 2014 through 2016), meeting the compliance requirement of 20% of retail sales in 2014 and 2015, and 25% of retail sales in 2016. The City also satisfied the RPS target for Compliance Period 3 (from 2017 through 2020), meeting the compliance requirement of 27% of retail sales in 2017, 29% of retail sales in 2018, 31% of retail sales in 2019, and 33% of retail sales in 2020), through the use of banked RECs from prior excess procurement. California Senate Bill 350 (“SB 350”) requires that the target amount of electricity generated each year from eligible Packet Pg. 400 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 28 4909-8297-8690v6/200986-0003
renewable energy resources be increased to at least 50% of total retail sales by December 31, 2030.
California Senate Bill 100 (“SB 100”) accelerates the State’s RPS target as established by SB 350 from 50% by 2030 to 60% by 2030 and sets interim compliance targets to achieve such goal. The City intends to exercise optional compliance measures in satisfaction of the interim target under SB 100 of 40% of retail sales to be made from eligible renewable energy resources from January 1, 2021 through December 31, 2024. In addition, the City is preparing to meet the accelerated eligible renewable energy compliance requirement of 60% of retail sales by December 31, 2030, including interim targets for 2025-29, in accordance with SB 100. The City has registered with WREGIS to track, transfer, retire and sell RECs.
The City’s RPS compliance obligation is increasing due to rising customer demand primarily driven by electrification adoption. The City intends to meet the RPS compliance targets, but plans to utilize eligible optional compliance measures in the event it falls short of the revised RPS requirements. See “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY – State Legislation and Regulatory Proceedings – California Renewables Portfolio Standard.” Distributed Energy–Solar Programs. In 2007, the City adopted a solar initiative program designed to meet Senate Bill 1 (“SB 1”) requirements for the promotion of solar photovoltaic projects through rebates and incentives. As of December 31, 2024, over 2,200 solar photovoltaic (“PV”) projects with a capacity of over 21 MW have been installed within the City. The projects range from 1 kW to 700 kW and are located on City-owned and customer-owned facilities throughout the City. The City offered significant rebates through September 30, 2010. The City Council approved a 700 kW project at the municipal airport in December 2010 which, combined with several other scalable sized projects, effectively exhausted funds available to incentivize solar photovoltaic projects with rebates through July 2014. In August 2014, the City reopened the rebate program with $700,000 in funding; those funds were exhausted in less than two business days through 105 applications with a total installed capacity of 1.3 MW. Since that time, the City has continued to see growth in installed PV systems. On September 13, 2016, the City again re-opened the solar rebate program and provided a $0.50/watt rebate, up to maximum of $5,000. After meeting the goals of SB 1, application for the program was closed on October 31, 2017 with approximately $1.1 million in rebates having been provided through December 31, 2017. The City continues to see additional PV system installations in the City, prompted at least in part by the California building code standards requirements for PV installations in various new construction residential and nonresidential buildings.
Energy Efficiency Programs
To operate cost-effectively, the City developed several load-management and energyconservation programs, including public awareness campaigns, technical conservation assistance, rebates on energy-efficient products and technologies, renewable technologies, and energy-efficient streetlights.
In Fiscal Year 2021-22, the City developed its Demand-Side Integrated Resource Plan (DSM-IRP) and determined that decarbonization programs (i.e., electrification) were more cost-effective than energyefficiency programs due to their ability to produce downward rate pressure from the increased retail load.
The electrification rebate programs, which help reduce carbon emissions by including incentives for switching appliances from natural gas to electric technologies, were launched at the beginning of Fiscal Year 2022-23. The City also developed various electrification programs for income-qualified customers, which provide electrification equipment and installation at no cost or point-of-sale vouchers for electric vehicle or e-bike purchases to reduce up-front costs.
Future Power Supply Resources
The City maintains a future power supply plan to ensure that resources to meet both the capacity and energy needs of the City (including reliability reserves) are planned, developed and tested before their load service duty begins. The City’s interest in the M-S-R PPA power purchase agreements for wind Packet Pg. 401 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 29 4909-8297-8690v6/200986-0003
energy from the Big Horn I Project (see “– Power Supply Resources – Joint Powers Agency Resources - Purchased Power, Generation and Transmission – M-S-R PPA Purchased Power–Big Horn I Wind Energy Project” above), account for nearly 25% of the City’s retail energy needs, and over 75% of its current renewable energy requirements. As part of its future power supply planning, the City is exploring options, such as new solar and storage projects, to replace the Big Horn Wind PPA starting in 2027. As noted above, the City is forecasted to have sufficient renewable resources to meet the minimum renewable energy procurement targets mandated by State law through approximately 2030. See “DEVELOPMENTS IN THE CALIFORNIA ENERGY MARKETS – State Legislation – Renewables Portfolio Standard.” Options for the City to meet increased requirements of any new legislation or requirements beyond 2030 would include: renewing current power purchase agreements for renewable energy; acquiring renewable energy through new power purchase agreements; acquiring new City-owned renewable projects; and/or purchasing qualifying RECs. These options are regularly assessed by the Electric Utility Department and explored in accordance with best utility practices to have the least impact on rates, reliability and safety. The City will continue to look for cost effective, conventional, and renewable resources that will complement the City’s existing diversified resource portfolio and reliably meet the future electricity needs of the City’s customers, as well as regulatory requirements.
Fuel Supply
Natural gas is the primary fuel and the primary variable operating cost of the Redding Power Plant. See “– Power Supply Resources – Generating Facilities – Redding Power Plant” above. The Redding Power Plant can require delivery of up to 40,000 million British Thermal Units (“MMBtu”) of natural gas per day, with current average daily requirements of 8,500 MMBtu per day. The City has developed a comprehensive natural gas program to both manage supply and price volatility. This includes the procurement of a supply of natural gas at a discount from the monthly index price pursuant to a gas prepayment arrangement, forward purchases of natural gas at fixed prices, and storage options.
M-S-R Energy Authority – Gas Prepay. The M-S-R PPA members have formed a joint powers authority known as the M-S-R Energy Authority (referred to herein as M-S-R EA). M-S-R EA was created for the purpose of entering into contracts and issuing bonds to assist the M-S-R EA participants in financing the acquisition of supplies of natural gas for use in each participant’s respective electrical generation stations. In 2009, the City participated in the M-S-R EA Gas Prepay Project. The Gas Prepay Project provides the City, through a Gas Supply Agreement with M-S-R EA (the “Gas Supply Agreement”), a reliable, long-term supply of natural gas of 5,000 MMBtu daily (or 1,825,000 MMBtu annually) through September 30, 2039. The Gas Supply Agreement provides this supply at a discounted price below the monthly market index price (the PG&E Citygate index) over the 30-year term. M-S-R EA entered into a prepaid gas purchase agreement with Citigroup Energy, Inc. (“CEI”) to provide this gas supply, and issued $200.4 million principal amount of its Gas Project Revenue Bonds, Series 2009C (the “M-S-R EA 2009C Gas Bonds”) to finance the prepayment for the City, of which $186.3 million was outstanding as of June 2, 2026. Under the terms of the Gas Supply Agreement, M-S-R EA will bill the City for actual quantities of natural gas delivered each month on a “take-and-pay” basis. The obligations of CEI are guaranteed by Citigroup Inc., and responsibility for bond repayment is non-recourse to the City. Moreover, any default by the other Gas Prepay Project participants, Modesto and Santa Clara, is also non-recourse to the City.
Fixed Price Forward Purchases. In addition to natural gas procured through the M-S-R EA Gas Prepay Project, the City has entered into a number of fixed price purchase agreements to purchase natural gas through Fiscal Year 2027-28. The following tables provides on a yearly basis, the amount and approximate purchase dollar amount of current fixed price natural gas purchases for which the City is obligated:
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Fixed Price Forward Natural Gas Purchases
Fiscal Year 2025-26 2026-27 2027-28
Dth/dy
(Decatherm per day) 7,479 3,500 1,750
Purchase Cost
($ in million) $14.1 $6.3 $3.5
$/Dth $5.15 $4.92 $5.48
Currently, the City’s forecasted gas requirements range from approximately 6,000 to approximately 10,000 Decatherms per day (“Dth/dy”) (a decatherm is equal to one MMBtu) for the next 10 years. The City employs a laddered hedging strategy with specified minimums when considering additional gas purchases; specifically, the smaller of the volume needed to hedge index priced gas or the forward generation requirement as then modeled to meet forecasted load.
In connection with the City’s gas hedging activities, the City may be required to post collateral to various counterparties based upon contract mark-to-market values and credit exposure limits under such contracts. During the last five years, the City has not been required to post collateral at any time. While the posting of collateral is not an expense to the City, it can encumber unrestricted cash balances when required.
Storage. To further manage seasonal, weather, and price volatility, the City has, since 2004, contracted for natural gas storage within California. In 2010, under a 28-year term contract with Gill Ranch Storage, the City commenced utilizing storage rights in Gill Ranch, a gas storage facility located in central California. Under the agreement, the City has leased cushion gas valued at $13.57 million to Gill Ranch Storage and Gill Ranch Storage provides the City with approximately 600,000 Dth of natural gas storage. At the end of the contract term in 2038, the cushion gas will be returned to the City, unless the lessee executes the option to purchase the gas. If the option is exercised, the purchase price will be equal to the original cost of the gas escalated at a rate of 1.08% per annum.
Interconnections, Transmission and Distribution
The City is a member of the Balancing Authority of Northern California (referred to herein as BANC). In January 2005, the City became part of the Sacramento Municipal Utility District (“SMUD”) balancing authority area. In May 2009, SMUD, the City, Modesto and Roseville executed a joint exercise of powers agreement creating BANC to consolidate balancing authority activities. The transition to operation of BANC occurred on May 1, 2011, at which time the operations of the SMUD balancing authority were turned over to BANC. Since that time, the Trinity Public Utilities District and the City of Shasta Lake have also become members of BANC. SMUD acts as the balancing authority operator under contract and performs balancing authority functions on behalf of BANC. As provided in the BANC member agreement, liability for penalties associated with balancing authority-related Reliability Standards are shared on a pro rata basis among the members of BANC. The BANC joint exercise of powers agreement assigns cost responsibility for BANC operations based on member load within the BANC balancing authority. The City’s cost responsibility share for BANC operations based upon BANC’s budget for 2026 is approximately 4.9%.
On April 3, 2019, SMUD, the largest BANC member, began its participation in the CAISO Energy Imbalance Market (“EIM”), a real-time wholesale power trading market that operates in parts of eight western states, including Washington, Oregon, California, Nevada, Idaho, Wyoming, Utah, and Packet Pg. 403 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 31 4909-8297-8690v6/200986-0003
Arizona. In addition to modest economic benefits, participation in the EIM is expected to enhance BANC members’ ability to integrate renewable energy, provide additional sources of real-time supply to augment reliability resources, increase regional resource diversity, and maintain access to a robust pool of resources and counterparties. The remaining BANC members, including the City, began participating in the EIM in March 2021.
Western’s Sierra Nevada region operates as a sub-balancing authority area within BANC’s balancing authority area. Western provides access to the City to Western’s high voltage transmission facilities via an interconnection with the City’s distribution system. Under a transmission service contract with Western, power needed to meet the City’s system loads that are not met by generation assets within its service area can be imported using Western transmission service. The City’s transmission service contract with Western, executed in August 1995, is effective for 40 years, subject to a termination right of either party upon five years’ notice. Under the transmission service contract, Western agrees to provide on a firm basis, both long-term transmission service and short-term COTP transmission service to the City.
As discussed herein, the City has firm transmission rights on the COTP. Through its participation in TANC, the City has firm transmission rights to approximately 148 MW of the COTP. The City gains access to its COTP participation rights though its transmission service contract with Western. See “– Power Supply Resources – Joint Powers Agency Resources – Purchased Power, Generation and Transmission – TANC California-Oregon Transmission Project” above.
Delivery of all power from sources outside of the City is made to the City at the Keswick Switchyard and the Airport 230/115 kV Substation. These two facilities provide the City with a reliable interconnection capacity of 275 MW from Western’s 230 kV transmission system. The City owns and operates a 115/13.8 kV generation step-up substation at the Redding Power Plant. The City also jointly owns the Airport Substation with Western. The City owns and operates 72 miles of 115 kV transmission system lines which deliver energy to 11 existing distribution substations that step the voltage down to 12 kV. The City also owns and operates 767 miles of 12 kV distribution system lines. The City’s system typically experiences approximately 49 minutes of outage time per customer per year (excluding major storm events).
Wholesale Energy Trading
As previously noted, the City plans for its future conventional and renewable power supplies. In addition to making market purchases when cost-effective, the City sells excess capacity and energy that is surplus to its needs. The City operates and manages its power supply and transmission resources using an “economic dispatch” model that is designed to produce energy at the lowest cost to reliably serve consumers, recognizing any operational limits of generation and transmission facilities. Under this model, the City participates in trading in the wholesale energy markets in order to capture the maximum value of its generation assets and to minimize the cost of purchased power. Additionally, the City optimizes its gas purchases and sales within the year to coordinate with wholesale energy costs. In the three Fiscal Years ended June 30, 2023 through June 30, 2025, gross revenue associated with these trading activities has averaged $32.826 million. Net revenue is significantly less but is not independently determinable as it is reflected in the overall cost to serve retail load. For financial forecasting and planning purposes, the City only assumes revenues from wholesale trading activities that are under contract at the time of the forecast.
The City expects to continue optimizing its generation and transmission assets using the wholesale market for the benefit of its retail electric customers and anticipates that wholesale trades will continue at some level in the future.
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Risk Management Program
In support of its wholesale market transactions, the Electric Utility Department has maintained a formal risk committee since September 17, 2001. A newly re-chartered Energy Risk Management Committee (“ERC”) was established on March 14, 2017. Energy Risk policies were revised in February 2024. The ERC meets periodically to implement risk policies, review wholesale market activities, and establish counterparty credit, among other activities.
As of the date of this Official Statement, the City has never experienced a loss as a result of credit quality or transaction performance defaults.
Cybersecurity Measures
The City has a computer usage and management of electronic records policy and has adopted a risk-based cybersecurity strategy. The Electric Utility Department has computer security procedures, and security practices documents. The Electric Utility Department launched a comprehensive upgrade to the cybersecurity program in 2021 that is compliant with the North American Electric Reliability Corporation (“NERC”) Critical Infrastructure Protection (“CIP”) Standards. NERC’s CIP Standards protect the critical infrastructure of the North American electric grid by establishing mandatory cybersecurity regulations designed to safeguard the Bulk Electric System from cyber threats, ensuring the reliable operation of the power grid by mitigating risks posed by cyberattacks on critical assets like power generation and transmission systems. These Reliability Standards were developed by NERC and approved by FERC pursuant to the Energy Policy Act of 2005 (“EPAct 2005”). See “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY – Federal Energy and Environmental Policies and Legislation – Energy Policy Act of 2005.” See also “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY – Federal Policy on Cybersecurity” and “– Cybersecurity Risks.” Wildfire Mitigation Measures
Approximately 50% of the territory of the City’s Electric System service area is in a geographical area classified by the CPUC’s Fire Threat Map as a “Tier 2” or “Tier 3” fire-threat area (i.e., an area of elevated or extreme risk from utility-associated wildfires), including 18,000 acres adjacent to Electric System equipment and facilities and 120 miles of overhead power lines. In connection with the operation of its facilities and equipment, the City currently has in place or is implementing a number of wildfire prevention strategies and programs. These programs and measures include ongoing vegetation management activities, annual inspection of overhead electric utility equipment, enhanced situational awareness though use of surveillance and communications technology, and the ability to eliminate the automatic restoration function on certain transmission lines to require that power to a tripped line is only restored after manual inspection and confirmation that it may be operated safely under established conditions. The City also has established protocols and procedures for operations for emergency preparedness and response. Pursuant to the requirements of SB 901, the City Council approved the City’s Wildfire Mitigation Plan on December 3, 2019. The City’s Wildfire Mitigation Plan (accompanied by an Independent Evaluator Report) was submitted to the Wildfire Advisory Board. The plan is updated annually, most recently in May 2025, consistent with statutory requirements, and with consideration of the recommendations of the Wildfire Advisory Board regarding its prior plans. See also “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY – State Legislation and Regulatory Proceedings – Legislation Relating to Wildfires; Related Risks” and “– Insurance” below.
In addition, the City has adopted a Community Wildfire Protection Plan, which was developed with an external consultant, and with collaboration from the Redding Fire Department, the Electric Utility Department, and other agencies. The Community Wildfire Protection Plan was prepared as a tool to Packet Pg. 405 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 33 4909-8297-8690v6/200986-0003
assess the City’s wildfire risks, community preparedness and defensibility, and to identify and provide potential wildfire hazard mitigation projects for the City. The City’s Community Wildfire Protection Plan was accepted by the City Council in January 2025. Significant fires can and have occurred in the City’s Electric System Service Area, including the Carr Fire in 2018. It is impossible to predict the occurrence and impact of future fires on the City or its Electric System.
Insurance
The insurable property and facilities of the Electric System are covered under the City’s general insurance program. The City’s insurance program currently consists of a combination of commercial insurance policies and self-insurance. Property insurance is administered as a co-insurance plan. The City is self-insured for claims up to $250,000 for all risk and up to $500,000 for wildfires. Additionally, the City has acquired coverages for Redding Power Plant up to $100 million, with various sub-limits and deductibles for different types of losses. The City does not insure its physical assets against the risk of physical loss or damage due to earthquakes. Effective January 1, 2025, the City has also secured certain cybersecurity insurance coverage to protect the Redding Power Plant assets.
The City is self-insured for general and liability claims up to $750,000. Any claims from $750,001 to $40.0 million are administered through a governmental pooling joint powers authority, the California Joint Powers Risk Management Authority. In addition, the City is self-insured up to $750,000 per claim for workers’ compensation claims, with an insurance company co-insuring claims from $750,001 to $50.0 million.
The City records liabilities for unpaid claims when they are probable of occurrence and the amount can be reasonably estimated. Funds determined to be at risk are charged a percentage of the total estimated insurance and claim expense. The City periodically evaluates its insurance program and may modify the current configuration of commercial insurance and self-insurance with respect to the City and the Electric System. Limits maintained by the City are subject to change depending on insurance market conditions and assessments by the City as to risk exposure.
Rates and Charges
The City Council is authorized by the Redding Municipal Code to establish electrical utility rates for all electric utility subscribers. Rate changes are not subject to regulatory agency review. The City has maintained rates sufficient, together with other available funds, to pay for (a) operations and maintenance of the system; (b) additions and betterments to the system; (c) amortization of all depreciation and obsolescence within the system; (d) all debt service liability incurred in the construction or extension of the system; and (e) establishment and maintenance of a reserve fund to provide for extensions and betterments of the system and unforeseen contingencies. See also “– Cash Reserves.” In December 2023, the City Council approved a change in electric rates (4.0% rate increases per year) effective with the January 2024 and January 2025 billing cycles, and an increase in the benefit of the residential energy discount for income-qualified households. The general rate increases of 4.0% per year are consistent with the anticipated rate increases contemplated in the City’s approved biennial budget for Fiscal Years 2023-24 and 2024-25, and the Electric System’s five-year financial plan presented in connection with such budget. The City is currently in the process of evaluating future increases in its electric rates.
The following table presents a history of electric rate increases for the last four years.
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CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
RATE INCREASES
Date Percent Change
January 1, 2025 4.00%
January 1, 2024 4.00
January 1, 2023 2.00
January 1, 2022 2.00
__________________
Source: City of Redding.
The City’s current primary rate schedules for residential, commercial and industrial customers of the Electric System are set forth below.
CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
PRIMARY RATE SCHEDULES FOR RESIDENTIAL, COMMERCIAL
AND INDUSTRIAL CUSTOMERS
(As of January 1, 2025)
Type and Description of Service
General Residential Service (Basic):
Fixed Charge, per meter, per month $ 40.00
Energy Charge (to be added to Network Access Charge):
Per kWh for all kWh in billing period 0.1492
Multi-Family Residential Service (Basic):
Fixed Charge, per meter, per month $ 38.00
Energy Charge (to be added to Network Access Charge):
Per kWh for all kWh in billing period 0.1492
General Service Small Commercial Customers:
Fixed Charge, per meter, per month $ 70.00
Energy Charge (to be added to Network Access Charge):
Per kWh for all kWh in billing period 0.1649
General Service Large Commercial and Industrial Customers:
Fixed Charge, per meter, per month $ 95.00
Energy Charge (to be added to Network Access Charge):
Per kWh for all kWh in billing period 0.1086
Demand Charge, per kW $ 21.50
__________________
Source: City of Redding.
The table below sets forth the average billing price per kWh for the various customer classes during the Fiscal Year 2024-25.
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CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
AVERAGE BILLING PRICE (CENTS) PER KILOWATT-HOUR
(RETAIL SALES)
(For Fiscal Year 2024-25)
Residential.............................................. $0.1838 Commercial ............................................ 0.1804 Industrial................................................. 0.2038 Other....................................................... 0.1924 System Averages.................................... 0.1833 __________________
Source: City of Redding.
Comparison of Selected Monthly Residential Electric Bills The City’s residential rates for average usage continue to be below PG&E’s rates (for other than baseline (subsidized) residential service). The following table shows a comparison of selected monthly residential electric bills for regional utilities as of August 2025.
COMPARISON OF SELECTED MONTHLY
RESIDENTIAL ELECTRIC BILLS
(As of August 2025)
850 kWh 1,500 kWh
Average Monthly Average Monthly
PG&E $369.62 $701.51
Modesto Irrigation District 215.84 369.50
SMUD 210.08 349.18
City of Palo Alto 198.98 355.75
Redding 167.93 265.75
Silicon Valley Power 149.25 264.80
Turlock Irrigation District 144.46 260.85
__________________
Notes:
Excludes state surcharge and taxes, if any.
Differences in time-of-use periods and rate adjustments make exact comparisons difficult.
Source: City of Redding.
Major Customers
Based upon energy usage for the Fiscal Year ended June 30, 2025, the ten largest electric utility accounts (including state and federal government accounts) of the City represent approximately 14.13% of total kWh sales and approximately 12.68% of total revenues. The largest account, the City’s other departments and activities, consumed approximately 4.29% of the electric utility’s total kWh sales and contributed approximately 4.09% of total revenues, and the smallest of the ten largest accounts consumed approximately 0.62% of total kWh sales and contributed approximately 0.52% of revenues.
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CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
TEN LARGEST CUSTOMERS(1)
(Fiscal Year 2024-25)
Customer
Total kWh
Usage
% of Total
System
Usage
Total
Electric
Charge
% of Total
System
Revenue
City of Redding 32,989,571 4.29% $5,824,233 4.09%
State of California 13,479,167 1.75 2,304,272 1.62
Mercy Healthcare Center 12,433,977 1.62 1,848,521 1.30
Shasta County 8,660,117 1.13 1,577,112 1.11
Prime Health Care Shasta LLC 9,813,392 1.28 1,481,504 1.04 Mt. Lakes Manufacturing LLC 7,301,200 0.95 1,233,632 0.87 Redding Rancheria Utility Corp 8,241,297 1.07 1,230,962 0.87 Saraf, Simmon 5,773,200 0.75 952,780 0.67
AT&T Services 5,058,275 0.66 839,806 0.59
Costco Utility Bills 4,792,400 0.62 740,204 0.52
Total 108,542,596 14.13% $18,033,026 12.68%
__________________
Source: City of Redding.
Customers, Sales, Revenues and Demand
The average number of customers, kWh sales, revenues derived from sales, by classification of service, and peak demand during the past five Fiscal Years, are listed below. Combined customer electric requirements created the City’s historic distribution system peak demand of 253.0 MW on July 24, 2006. [Remainder of page intentionally left blank.]
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CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
CUSTOMERS, SALES, REVENUES AND DEMAND
(Fiscal Years Ended June 30)
2021 2022 2023 2024 2025
Number of Customers(1):
Residential...................... 38,587 38,572 38,706 39,019 39,089 Commercial.................... 4,975 5,088 5,092 5,101 5,212 Industrial ........................ 353 351 336 326 329 Other............................... 966 970 974 967 961 Total Customers.......... 44,881 44,981 45,108 45,413 45,591 Kilowatt-Hour Sales:
Residential...................... 393,403,666 375,817,815 394,986,058 372,342,493 392,467,877 Commercial.................... 302,067,356 300,596,737 308,605,996 305,667,285 315,896,990 Industrial ........................ 11,552,342 12,155,405 12,152,344 12,127,995 12,876,886 Other............................... 50,105,459 49,924,125 46,678,248 46,467,017 49,253,384 Total kWh ................... 757,128,823 738,494,082 762,422,646 736,604,790 770,495,137 Revenues from Sale of
Energy:
Residential...................... $ 64,644,393 $ 61,245,910 $ 66,247,872 $ 65,060,311 $ 72,152,657 Commercial.................... 48,851,836 49,535,399 52,376,793 53,321,173 57,003,353 Industrial ........................ 2,168,208 2,273,909 2,366,791 2,411,381 2,624,585 Other............................... 8,085,886 8,200,232 8,029,169 8,598,261 9,474,696 Total Revenues from
Sale of Energy(2): .... $123,750,323 $121,255,450 $129,020,625 $129,391,126 $141,255,291 Peak Demand (kW) ........... 225,400 233,900 239,100 234,200 240,900 __________________
(1) The Number of Customers values includes every point at which electricity is used as of the last month of the Fiscal Year.
(2) Differs from Retail Revenue as shown in the table entitled “Summary of Financial Operating Results” due to timing differences in meter readings, accruals and billings in the application of data for billing system and accounting system data.
Source: City of Redding, Utility Billing System Detailed Marketing Report of Quarterly NAICS Usage.
All electric bills are due and payable upon receipt of billing and become delinquent 20 days thereafter. If such bills remain unpaid on the 42nd day after billing, all electric services are subject to termination until all fees, charges, penalties and the entire delinquent balance have been paid. Delinquent fees and charges may be made a lien against the property, placed on the tax roll of Shasta County and collected in the same manner as ad valorem taxes.
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The City considers its write-offs for uncollectible accounts to be low by electric utility industry standards for urban areas. The write-offs for uncollectible accounts for the past five Fiscal Years are presented in the following table:
CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
UNCOLLECTIBLE REVENUES
As of
June 30
Uncollectible
Revenues
Percent of
Gross Billings
2021 230,576 0.18
2022 1,947(1) < 0.01(1)
2023 289,651 0.22
2024 178,072 0.13
2025 225,431 0.16
__________________
(1) The lower uncollectible revenues in Fiscal Year 2022 reflects the recovery by the City for past due accounts under the 2021 California Arrearage Payment Program (CAPP) which provided financial assistance for California energy utility customers to help reduce past due energy bill balances that were incurred during the COVID-19 pandemic.
Source: City of Redding.
Transfers to the General Fund
Commencing with Fiscal Year 1988-89, it has been the practice of the Electric System to make a monthly payment in-lieu of taxes (“PILOT”) to the City’s general fund, in addition to paying its proportionate share of the City’s operating expenses attributable to the Electric System. The City’s payment in-lieu of taxes represents 1% of installed assets with selected depreciation. For the Electric System, this formula includes the system’s share of joint powers agency installed assets, and currently results in an in-lieu payment of approximately 5.03% of budgeted retail revenues.
The following table sets out the transfers from the electric utility to the City’s general fund for the five Fiscal Years 2020-21 through 2024-25 and the budgeted transfer for Fiscal Year 2025-26.
CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
TRANSFERS TO THE GENERAL FUND
Fiscal Year Transfer Amount
2020-21 $6,097,590
2021-22 5,464,000
2022-23 6,246,800
2023-24 7,270,600
2024-25 6,614,200
2025-26
(1) 5,996,600
__________________
(1) Fiscal Year 2025-26 Budgeted amount.
Source: City of Redding.
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Litigation challenging the PILOT was filed against the City in 2011. On August 27, 2018, the California Supreme Court rendered a decision upholding the City’s PILOT. See “CONSTITUTIONAL LIMITATIONS IN CALIFORNIA ON TAXES AND FEES.”
Capital Requirements
The City expects capital requirements for general Electric System improvements to average approximately $8.75 million per year for the next five Fiscal Years. The planned improvements primarily consist of ongoing routine capital projects for the Electric System, including transmission and distribution system improvements, such as construction of distribution lines, property acquisition, transformers, poles, conductors, metering equipment, and other miscellaneous routine capital facilities. In addition to the ongoing routine capital requirements, the City’s capital plan for the next five years includes the expenditure of approximately $7.0-8.0 million per year for special projects, including substation construction, and the funding of scheduled generation facility improvements and enhancements. The City currently expects that these capital requirements will be funded primarily from Electric System Revenues and proceeds of the 2025 RJPFA Electric System Bonds.
Employees
Labor Relations. As of June 30, 2025, the Electric Utility Department had 202.0 authorized fulltime equivalent (“FTE”) staff positions, including 173.5 FTEs for the Electricity Services Divisions, 18.5 FTEs for the Customer Service Division and 10.0 FTEs for the Field Service (meter reading) Division.
Distribution, Field Services, and Generation employees (made up of three bargaining units:
Electric, Maintenance and Power Production) are represented by the International Brotherhood of Electric Workers under labor contracts (“MOUs”) which expire or expired as follows: (i) Electric bargaining unit, MOU expiring November 7, 2026; (ii) Maintenance bargaining unit, MOU expired December 3, 2025 (negotiations for a new MOU are underway) and (iii) Power Production bargaining unit, MOU expiring April 4, 2026 (negotiations for a new MOU are underway). Clerical employees (made up of two bargaining units: Supervisory/Confidential and Clerical, Technical and Professional) are represented by Redding Independent Employees Organization (“RIEO”) under labor contracts which expired on July 19, 2025 (negotiations for a new MOU are underway, but have reached an impasse). Technical office employees throughout the utility are represented by United Public Employees of California under labor contracts which expire on June 30, 2026 (negotiations are scheduled to begin the last week of January 2026). The City and all other employee organizations are continuing to negotiate successor labor contracts. Until successor contracts are executed, the terms of the expired contracts will continue to govern. Management and professional employees receive substantially the same fringe benefit package as the represented employees. Redding’s wage and fringe benefits are generally comparable to those offered by other local public agencies.
Pension Plans. Retirement benefits to City employees, including those assigned to the Electric Utility Department, are provided through the City’s participation in the California Public Employees Retirement System (“CalPERS”), an agent multiple-employer plan administered by CalPERS, which acts as a common investment and administrative agent for participating public employers within the State.
CalPERS issues a separate annual comprehensive financial report. Copies of the CalPERS annual financial report may be obtained from the CalPERS Executive Office, 400 Q Street, Sacramento, California 95814.
The City’s defined benefit pension plans, the Miscellaneous Plan and the Safety Plan of the City of Redding, provide retirement and disability benefits, annual cost-of-living adjustments, and death benefits to plan members and beneficiaries. Benefit provisions under the plans are established by State Packet Pg. 412 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 40 4909-8297-8690v6/200986-0003
statute and local government resolution. No employees assigned to the Electric Utility Department participate in the Safety Plan.
The cost of the Miscellaneous Plan is funded through bi-weekly contributions from employees and from employer contributions by the City. Active Miscellaneous Plan members hired prior to January 1, 2013 are required to contribute 7.00% of their annual covered salary and those hired on or after January 1, 2013 are required to contribute 8.00% of their annual covered salary. The member contribution can be paid by the employee or by the City on the employee’s behalf in accordance with applicable labor agreements. The required member contributions are currently paid by the employees. The City’s employer contribution rate is determined annually by the actuary effective on the July 1 following notice of a change in rate. Funding contribution amounts are determined annually on an actuarial basis as of June 30 by CalPERS. The actuarially determined rate is the estimated amount necessary to finance the costs of benefits earned by employees during the year, with an additional amount to finance any unfunded accrued liability. The City is required to contribute the difference between the actuarially determined rate and the contribution rate of employees. The actuarial methods and assumptions used are those adopted by the CalPERS Board of Administration. The contribution requirements of the plan members are established by State statute and the employer contribution rates are established, and may be amended, by CalPERS.
In addition to the defined pension plan through CalPERS, the City approved the establishment of a Public Agency Retirement System (“PARS”) defined benefit Retirement Enhancement Plan (“REP”) effective January 1, 2005, in order to provide a supplemental retirement benefit for all eligible City employees, including those assigned to the Electric Utility Department. The REP is an agent multipleemployer defined benefit plan. Pursuant to the California Public Employees’ Pension Reform Act of 2013, as of January 1, 2013 the REP is closed to new participants. Employees are required to contribute between 1.71% and 2.70% of their of their annually covered salary to the REP to participate. Active represented REP members (not including management and professional employees) assigned to the Electric Utility Department are not required to contribute to the REP to participate. The City is required to make all other required contributions to fund the REP benefits for participating members. The REP became fully funded in fiscal year 2025-26.
The Electric Utility Department is allocated its portion of the City’s required contributions for the Miscellaneous Plan and the REP. This allocation is based on eligible employee wages.
The table below sets forth the Electric Utility Department’s allocated share of the City’s actuarially determined required contributions to the Miscellaneous Plan and the REP Plan for the past five Fiscal Years and the amount budgeted for its allocated share of the City’s estimated required contributions to such plans for the current Fiscal Year.
Miscellaneous Plan REP Plan
Fiscal Year
Electric Utility
Department
Allocated Share
of Contribution
Total City
Required
Contribution
Amount
Electric Utility
Department
Allocated Share
of Contribution
Total City
Required
Contribution
Amount
2020-21 $5,788,940 $15,066,353 $2,639,123 $7,158,333
2021-22 6,563,152 16,765,328 3,645,286 9,589,481
2022-23 7,364,449 18,428,744 3,634,079 9,823,669
2023-24 7,501,976 19,675,937 7,595,688 17,077,760
2024-25 8,748,942 22,652,395 3,326,323 7,481,977
2025-26(1) 9,161,666 24,128,798 77,261(2) 255,893(2)
Packet Pg. 413 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 41 4909-8297-8690v6/200986-0003
(1) Fiscal Year 2025-26 Budgeted amounts.
(2) The REP Plan became fully funded in fiscal year 2025-26.
Source: City of Redding.
The market value of assets for the Miscellaneous Plan as of June 30, 2024 (the most recent actuarial information available) was $382,090,536 and the entry age normal accrued liability was $595,447,797, resulting in a total unfunded actuarial accrued liability for the City’s Miscellaneous Plan of $213,357,261 and a funded ratio of 64.2% as of such date. The market value of assets for the REP as of July 1, 2023 (the most recent actuarial information available) was $79,545,153 and the actuarial accrued liability was $94,451,621, resulting in a total unfunded actuarial accrued liability for the REP of $14,906,468 and a funded ratio of 84.22% as of such date.
The City’s required contributions to CalPERS fluctuate each year and include a normal cost component and a component equal to an amortized amount of the unfunded liability. Many assumptions are used to estimate the ultimate liability of pensions and the contributions that will be required to meet those obligations. The CalPERS Board of Administration has adjusted and may in the future further adjust certain assumptions used in the CalPERS actuarial valuations, which adjustments may increase the City’s required contributions to CalPERS in future years. Actuarial assumptions used by PARs in calculating actuarially determined contributions and other actuarially determined amounts are generally consistent with those used by CalPERS. Accordingly, the City cannot provide any assurances that the City’s required contributions to CalPERS and PARS in future years will not significantly increase (or otherwise vary) from any past or current projected levels of contributions.
The announcement on July 12, 2021 that CalPERS achieved a preliminary investment return of
21.3% for the period from July 1, 2020 through June 30, 2021 caused the CalPERS Board of Administration to lower CalPERS’ discount rate from 7.0% to 6.8% on November 15, 2021 in accordance with a risk mitigation policy that was adopted in 2015, which calls for the discount rate to be lowered if returns exceed the then-current discount rate by two or more percentage points. Lowering the discount rate generally means that employers which contract with CalPERS to administer their pension plans will see increases in their normal costs and unfunded actuarial liabilities.
Effective for the Fiscal Year ended June 30, 2015, the City adopted Governmental Accounting Standards Board (“GASB”) Statement No. 68 (“GASB 68”), affecting the reporting of pension liabilities for accounting purposes. Under GASB 68, the City is required to report the Net Pension Liability (i.e., the difference between the Total Pension Liability and the Pension Plan’s Net Position or market value of assets) in its financial statements. The GASB 68 standards apply to financial reporting but not to the actuarial calculation of annual employer pension contributions, which continue to be determined actuarially by each plan.
The table below summarizes certain information relating to the Net Pension Liability of the Miscellaneous Plan and the REP Plan for the measurement periods ended June 30, 2020 through June 30, 2024, as reported in the City’s audited financial statements for the Fiscal Year ended June 30, 2025. [Remainder of page intentionally left blank.]
Packet Pg. 414 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 42 4909-8297-8690v6/200986-0003
Miscellaneous Plan(1) REP Plan(2)
Measurement
Period
Net Pension
Liability
Net Position
as a % of
Total
Pension
Liability
Net Pension
Liability as a
% of
Covered
Payroll
Net Pension
Liability
Net Position
as a % of
Total
Pension
Liability
Net Pension
Liability as a
% of
Covered
Payroll
2019-20 157,087,984 66.95 365.54 29,044,412 67.27 135.25 2020-21 109,430,508 77.67 243.93 14,809,606 83.65 73.46 2021-22 178,526,513 65.77 368.82 22,940,246 75.37 119.84 2022-23 190,628,671(3) 65.13 359.02 14,906,468(4) 84.22 77.52 2023-24 191,667,956(5) 66.60 359.02 (1,374,081)(6) 101.40 (6.99) __________________
(1) Measured using prior fiscal year annual actuarial valuation rolled forward to measurement date using standard update procedures.
(2) Determined by actuarial valuation as of valuation date projected forward to the measurement date. (3) $72,682,269 of the Net Pension Liability of the Miscellaneous Plan as of June 30, 2023 was determined to be allocable to the Electric Utility Fund.
(4) $6,629,962 of the Net Pension Liability of REP Plan as of June 30, 2023 was determined to be allocable to the Electric Utility Fund.
(5) $74,027,130 of the Net Pension Liability of the Miscellaneous Plan as of June 30, 2024 was determined to be allocable to the Electric Utility Fund.
(6) $(610,885) of the Net Pension Liability of REP Plan as of June 30, 2024 was determined to be allocable to the Electric Utility Fund.
Source: City of Redding.
As of the June 30, 2024 measurement date, the city-wide Total Pension Liability for the Miscellaneous Plan was $573,939,461 and the Plan Fiduciary Net Position was $382,271,506, resulting in the city-wide Miscellaneous Plan Net Pension Liability of $191,667,955. In the June 30, 2023 actuarial valuation utilized for measuring the pension liability for the Miscellaneous Plan as of the June 30, 2024 measurement date, the Entry Age Normal Actuarial Cost Method was used. The actuarial valuation assumptions used for determining pension liabilities included (a) a 7.00% investment rate of return (net of pension plan investment expenses); (b) projected salary increases that vary based on age and type of service; (c) an inflation component of 2.50% per year; (d) payroll growth of 2.75%; and (e) a discount rate of 6.90%.
As of the June 30, 2024 measurement date, the Total Pension Liability for the REP was $98,393,890 and the Plan Fiduciary Net Position was $99,767,971, resulting in the REP Net Pension Liability of $(1,374,081). In the June 30, 2023 actuarial valuation utilized for measuring the pension liability for the REP as of the June 30, 2024 measurement date, the Entry Age Normal Actuarial Cost Method was used. The actuarial valuation assumptions used for determining pension liabilities included (a) a 7.00% investment rate of return; (b) projected salary increases that were graded rates based on years of service, and 3.34% after 30 years of service; (c) an inflation component of 2.30% per year; and (d) a discount rate of 7.00%.
Retiree Health Benefits. The City also provides medical and dental benefits to eligible City employees and their spouses, including City employees assigned to the Electric Utility Department, who retire from the City, through the City of Redding PARS Post-Retirement Health Care Plan (the “OPEB Plan”). The OPEB Plan is a single-employer defined benefit healthcare plan administered by Phase II Systems, dba Public Agency Retirement Services. The Redding City Council has the authority to establish and amend benefit provisions to the OPEB Plan. The authority for this coverage is union contracts for union employees and council resolution for all other employees. The contribution requirements of the plan members are established and may be amended by the Redding City Council. The Packet Pg. 415 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 43 4909-8297-8690v6/200986-0003
required contribution is based on projected pay-as-you-go financing requirements, with an additional amount (if any) to pre-fund benefits as determined annually by the Redding City Council. The City does not, and historically did not, pre-fund any portion of the plan. The City’s cost of current premiums, financed on a pay-as-you-go basis, can be up to 50% of the premium costs (with the remaining portion paid by retirees) based on employee years of service, subject to each of the City’s eight labor organization/employee group’s bargaining agreements. The Electric Utility Department is allocated its portion of the City’s annual full cost for current premiums based on employee eligibility.
Effective beginning for Fiscal Year 2017-18, the City follows the provisions of GASB Statement No. 75, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (“GASB No. 75”) affecting the reporting of OPEB liabilities for accounting purposes. GASB No. 75 establishes standards for employers with other postemployment liabilities for recognizing and measuring net OPEB liabilities, along with deferred inflows and outflows of resources, and expenses/expenditures related to the other postemployment liability. GASB No. 75 does not establish requirements for funding.
The table below sets forth the certain information regarding the City’s annual actuarially determined contribution, the Electric Utility Department’s allocated share of the City’s contribution amount for the OPEB plan, the contribution deficiency or excess and the Net OPEB liability. The actuarially determined contribution represents the level of funding that, if paid on an ongoing basis, is projected to cover normal cost each year and amortize any unfunded liabilities over a closed period not to exceed 30 years. As noted above, the City does not currently pre-fund any portion of the plan.
OPEB Plan
Fiscal Year
Electric Utility
Department
Allocated Share of
Contribution
City
Required
Contribution
Contribution
Deficiency (Excess)
Net OPEB
Liability(1)
2020-21 $988,708 $3,646,314 -- $40,637,719
2021-22 1,238,492 4,601,018 -- 54,940,168
2022-23 788,709 3,021,637 -- 51,564,892
2023-24 1,135,258 4,312,188 -- 78,992,811(2)
2024-25 1,242,091 4,633,703 [_______] 80,141,961
2025-26(3) 1,006,340 4,668,240 [_______](4) [_______](4) __________________
(1) As reported for such fiscal year based on prior fiscal year measurement period. (2) $20,796,229 of the Net OPEB Liability as of the June 30, 2023 measurement date was determined to be allocable to the Electric Utility Fund.
(3) Fiscal Year 2025-26 Budgeted amounts.
(4) Information not yet available.
Source: City of Redding.
Pursuant to GASB No. 75, for the Fiscal Year ended June 30, 2025, the City reported a Net OPEB Liability of $80,141,961 as of the June 30, 2024 measurement date, of which $21,482,516 was allocable to the Electric Utility Fund. The covered payroll (annual payroll of active employees covered by the OPEB Plan was $87,775,715 and the ratio of the Net OPEB liability to the covered payroll was
91.30%. The Net OPEB Liability was measured as of June 30, 2024, and the actuarial valuation used to calculate the Net OPEB Liability was as of June 30, 2024. In the June 30, 2024 actuarial valuation, the actuarial assumptions used in determining the Total OPEB liability include (a) a 3.93% discount rate at June 30, 2024 and a 3.65% discount rate at June 30, 2023; (b) a 3.50% expected net long-term investment rate of return at June 30, 2024 and 2023; (c) aggregate projected salary increases of 2.75% annually; Packet Pg. 416 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 44 4909-8297-8690v6/200986-0003
(d) an inflation component of 2.50% per year; and (e) a healthcare cost trend of 8.50% for 2025, decreasing to an ultimate rate of 3.45% in year 2076 for Non-Medicare participants, and 7.50% for 2025, decreasing to an ultimate rate of 3.45% in year 2076 for Medicare participants.
Additional information regarding the City’s retirement plans and other post-employment benefits, including further information regarding the assumptions used to determine the pension and OPEB liabilities and the funding requirements therefor, can be found in Notes 16 and 17 and the Required Supplementary Information to the City’s audited financial statements included in Appendix A hereto and in the City’s annual comprehensive financial report (“ACFR”) which may be obtained at the following website:
https://www.cityofredding.gov/government/departments/finance/accounting/financial_reports/index.php# Doc2849.
Indebtedness
Parity Electric Revenue Obligations. As of June 2, 2026, the City had $127,710,000 outstanding aggregate principal amount of long-term Electric System obligations constituting Parity Obligations and payable from Net Revenues of the Electric System and amounts on deposit in the Electric Revenue Fund on a parity with the 2026 Bonds consisting of: (i) the installment sale payments payable under the installment sale agreement relating to the 2015 RJPFA Electric System Bonds (which are being refunded with the proceeds of the 2026 Bonds); (ii) the 2017 City Electric System Refunding Bonds, (iii) the 2018 City Electric System Refunding Bonds and (iv) the installment sale payments payable under the installment sale agreement relating to the 2025 RJPFA Electric System Bonds. All of the outstanding Parity Obligations bear interest at a fixed rate. The outstanding Parity Obligations are summarized in the table below.
CITY OF REDDING
OUTSTANDING ELECTRIC SYSTEM INDEBTEDNESS
(as of June 2, 2026)
Name of Issue
Original Principal
Amount
Principal Amount
Outstanding
RJPFA Bonds
Electric System Revenue Bonds, 2015 Series A ....................... $ 37,955,000 $23,750,000(1) Electric System Revenue Bonds, 2025 Series A ....................... 67,175,000 66,045,000 City Refunding Bonds
Electric System Refunding Revenue Bonds, Series 2017 ......... 55,785,000 22,945,000 Electric System Refunding Revenue Bonds, Series 2018 ......... 39,510,000 14,970,000 Total $200,425,000 $127,710,000
__________________
(1)To be refunded with proceeds of the 2026 Bonds. See “PLAN OF REFUNDING.” Source: City of Redding.
See also APPENDIX G – “DEBT SERVICE SCHEDULE” for information regarding the City’s annual debt service requirements for the outstanding Parity Obligations.
Subordinate Revolving Credit Agreement. The City and the Authority have entered into the Revolving Credit Agreement with the Credit Bank, under which the Credit Bank has agreed to advance funds to the Authority, from time-to-time, in an amount up to $25,000,000, for the benefit of the City, in order to provide liquidity to the City, if necessary. Such funds may be borrowed, paid down, and rePacket Pg. 417 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 45 4909-8297-8690v6/200986-0003
borrowed under the terms of the Revolving Credit Agreement through November 1, 2028, unless such commitment by the Credit Bank to advance funds thereunder is earlier terminated pursuant to its terms.
The obligation of the Authority to repay borrowings advanced by the Credit Bank under the Revolving Credit Agreement is evidenced by promissory notes of the Authority (which may be taxable or taxexempt, as applicable), which notes are payable from, and secured by, certain installment sale payments required to be made by the City to the Authority under the terms of the Subordinate Installment Sale Agreement by and between the City and the Authority. The installment sale payments to be made by the City under the Subordinate Installment Sale Agreement constitute Subordinate Obligations, payable from Net Revenues of the City’s Electric System subject and subordinate to the City’s obligation to make payments with respect to the 2026 Bonds and the other Parity Obligations.
Notes under the Revolving Credit Agreement bear interest at a fluctuating rate of interest per annum equal to: (a) for taxable borrowings, the one-month secured overnight financing rate plus
0.11448% as determined in accordance with the Revolving Credit Agreement for each monthly interest accrual period (“Term SOFR”) plus a spread of 0.75% (so long as the current credit ratings on the City’s senior lien Parity Obligations are maintained); and (b) for tax-exempt borrowings, 85% of the Term SOFR plus a spread of 0.65% (so long as the current credit ratings on the City’s senior lien Parity Obligations are maintained). Any outstanding borrowings under the Revolving Credit Agreement which have not been paid (which borrowings may be paid from, among other sources, proceeds of future longterm financings of the City or the Authority) on or prior to the facility maturity date of the Revolving Credit Agreement (i.e., currently November 1, 2028, unless extended) will be automatically converted to term loans on such date, so long as no default or event of default by the Authority or the City shall have occurred and be continuing and all representations and warranties of the Authority and the City under the Revolving Credit Agreement are true and correct in all material respects as of such date. Any term loans made by the Credit Bank under the Revolving Credit Agreement will bear interest at a fluctuating rate of interest per annum equal to, for each day: (1) during the first 90 days commencing on the facility maturity date, the greatest of (i) the Prime Rate in effect at such time plus 1.0%; (ii) the Federal Funds Rate in effect at such time plus 2.0%; and (iii) 7.5% (such applicable rate, the “Base Rate”); and (2) during the period commencing on the 91st day after the facility maturity date to and including the 180th date after the facility maturity date, the Base Rate then in effect plus 1.0%; and (3) during the period commencing on the 181st day after the facility maturity date and thereafter, the Base Rate plus 2.0%. Principal on any such term loans would be payable in quarterly installments over three years.
Under the Revolving Credit Agreement, upon a failure by the Authority to pay principal or interest of any borrowing thereunder, a failure by the Authority or the City to perform or observe its covenants, a default by the Authority or the City in the payment of other specified indebtedness payable from Net Revenues of the Electric System, certain acts of bankruptcy or insolvency, or other specified events of default (including if any of Moody’s, S&P or Fitch shall have assigned a credit rating below “Baa1” or “BBB+” to any of the senior lien Parity Obligations, or any credit rating assigned by any of such rating agencies has been suspended or withdrawn for any credit related reason), the Credit Bank has the right to terminate its commitment to extend further credit under the Revolving Credit Agreement and may accelerate (depending on the event, seven days after the occurrence, or for certain events, only after 180 days’ notice, or, in connection with certain acts of bankruptcy or insolvency or in the event of an acceleration or right to cause an acceleration of Authority or City debt by another lender, credit enhancer or swap counterparty, immediately) the Authority’s obligation to repay any borrowings under the Revolving Credit Agreement. Upon the occurrence and during the continuance of an event of default under the Revolving Credit Agreement, outstanding borrowings thereunder may bear interest at a default rate equal to the then applicable Base Rate plus a spread of 4.0%.
As of June 2, 2026, the aggregate principal amount of borrowings outstanding under the Revolving Credit Agreement was $0.
Packet Pg. 418 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 46 4909-8297-8690v6/200986-0003
Take-or-Pay; Joint Powers Agency Obligations. As previously discussed, the City participates in several joint powers agencies, including M-S-R PPA, M-S-R EA and TANC, which have issued joint powers agency indebtedness to finance the costs of certain projects on behalf of their respective project participants. The City does not participate in any NCPA-financed generation or transmission projects and therefore has no obligation in connection with any NCPA indebtedness. Obligations of the City under its agreements with respect to M-S-R PPA and TANC constitute Maintenance and Operation Costs of the Electric System payable prior to any payments required to be made in connection with the 2026 Bonds and the City’s other Parity Obligations described above. Agreements with M-S-R PPA and TANC are on a “take-or-pay” basis, which requires payments to be made whether or not projects are completed or operable, or whether output from such projects is suspended, interrupted or terminated. These agreements contain “step-up” provisions obligating the City to pay a share of the obligations of a defaulting participant. As described herein, the City also participates in M-S-R EA and has certain payment obligations in connection therewith which constitute Maintenance and Operation Costs of the City’s Electric System. However, the City’s payment obligation to M-S-R EA is with respect to actual quantity of natural gas delivered each month on a take-and-pay (rather than take-or-pay) basis. Responsibility for bond repayment is non-recourse to the City. See “– Fuel Supply – M-S-R Energy Authority – Gas Prepay” above.
All of M-S-R PPA’s debt was retired as of July 1, 2022. The City’s participation and share of debt service obligation (without giving effect to any “step-up” provisions) for the TANC COTP project in which it participates are shown in the following table.
CITY OF REDDING
ELECTRIC UTILITY DEPARTMENT
OUTSTANDING DEBT OF JOINT POWERS AGENCIES
(Dollar Amounts in Millions)
(as of June 2, 2026)
Outstanding
Debt(1)
City
Participation(2)
City Share of
Outstanding
Debt
TANC
COTP Bonds....................................... $128.0 8.36%(3) $10.7 COTP Notes........................................ 91.7 10.04%(3) 9.2 Total $219.7 $19.9
__________________
(1) Outstanding principal amount.
(2) Participation obligation is subject to increase upon default of another project participant. Such increase should not exceed, without prior written consent of a non-defaulting participant, an accumulated maximum of 25% of such non-defaulting participant’s original participation. (3) As described herein, the City’s obligation for debt service differs from its TANC COTP entitlement participation percentage due to the varying shares of each TANC member-participant with respect to prior bond issues refunded by the outstanding TANC bonds and the portion of bonds allocable to South of Tesla transmission.
Source: City of Redding.
For the fiscal year ended June 30, 2025, the City’s annual obligations for debt service in connection with the TANC COTP joint powers agency obligations described in the table above aggregated approximately $1.3 million. The City’s share of debt service on such TANC COTP joint powers agency obligations is expected to increase, with the City’s annual obligations for debt service costs estimated at approximately $1.3 million in fiscal year 2025-26 through fiscal year 2038-39 (the final Packet Pg. 419 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 47 4909-8297-8690v6/200986-0003
maturity of the TANC COTP bonds). This projection does not include any future debt issuances that may occur. The outstanding TANC COTP bonds included in the above table are fixed rate debt. As described under “– Power Supply Resources – Joint Powers Agency Resources – Purchased Power, Generation and Transmission – TANC California-Oregon Transmission Project,” in August 2024, and extended in August 2025, TANC authorized the issuance pursuant to the TANC Credit Agreement of up to $120.0 million of variable rate TANC short term notes to be outstanding at any time for the purpose of financing certain improvements to the COTP on an interim basis. TANC short term notes issued pursuant to the TANC Credit Agreement will mature in September 2027 (with a corresponding amount proportionate to the City’s debt service obligations under the TANC Agreement due from the City), unless the commitment of the lender under the TANC Credit Agreement is extended in accordance with its terms. It is expected that TANC will refinance any TANC short term notes issued pursuant to the TANC Credit Agreement from the proceeds of TANC bonds on or before their maturity date. The City will be obligated to pay approximately 10.04% of TANC’s debt service on any such future TANC indebtedness.
Cash Reserves
The City maintains cash reserves for a number of reasons, including operating cash requirements, construction cash requirements, dealing with the cost impacts of dry hydroelectric conditions, gas and electric market volatility, and to allow the City the flexibility to increase rates on a scheduled basis. When circumstances warrant, the City has determined that it is appropriate to use a portion of its unrestricted cash balances and reserves to stabilize or subsidize its electric rates in the near term and to increase rates when appropriate.
In November 2014, the City Council adopted the Electric Utility Financial Management Policy (the “Electric Utility Financial Management Policy”), which became effective January 1, 2015. The Electric Utility Financial Management Policy establishes guidelines for prudently managing the financial profile of the City electric utility, including a target of 1.80 times debt service coverage without use of reserves; and a target of unrestricted reserves sized at a minimum of 75 days’ cash up to 180 days’ cash.
The Electric Utility Financial Management Policy also recommends that the City Council consider different rate adjustments under different conditions.
In Fiscal Year 2021-22, in alignment with the quarterly financial updates presented to the City Council, the Electric Utility Department allocated a portion of its cash reserves to help offset operational costs for the fiscal year. The actual cost of Redding Power Plant generation was higher than forecast due to an increase in load, the ongoing drought’s impact on hydroelectric deliveries, the price of natural gas due to the war in Ukraine, and the inclusion of gas purchases for wholesale energy sales. As of June 30, 2025, the level of unrestricted operating cash reserves maintained by the Electric System was approximately $45.2 million, representing 123 days’ of operating cash on hand. The current minimum unrestricted operating cash balance, as established by the Electric Utility Financial Management Policy, would be approximately $27.5 million.
In addition to unrestricted operating cash reserves addressed in the Electric Utility Financial Management Policy, the electric utility currently maintains a variety of other cash reserves, which together with the Electric Utility Financial Management Policy reserve amount totaled approximately $73.0 million as of June 30, 2025. These available cash reserves (as reflected in the table entitled “Summary of Operating Results” below) include certain set-aside amounts that are excluded for purposes of the Electric Utility Financial Management Policy reserve calculation.
Collectively, these reserves are designated to help insulate the City from market volatility. In addition, the documents pursuant to which the City’s outstanding Parity Obligations were issued or incurred permit the use of unrestricted cash balances and reserves to satisfy the City’s rate covenants with Packet Pg. 420 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 48 4909-8297-8690v6/200986-0003
its bond holders. These reserves are not available for transfer to the City’s general fund. The City Council has a policy that limits in-lieu transfers to the general fund to 1% of the electric utility’s asset base each year. See “– Transfers to the General Fund” above.
City Investment Policy
Funds of the City which are not pledged for the payment of debt are invested by the City Treasurer in accordance with the City’s Investment Policy. Allowable investments under the Investment Policy are those authorized by California Government Code Sections 53600 et seq. The Investment Policy is reviewed and updated if necessary no less than annually. The current Investment Policy was most recently approved by the City Council on July 30, 2024.
The Investment Policy may be changed at any time at the discretion of the City Council (subject to the State law provisions relating to authorized investments) and as the California Government Code is amended. There can be no assurance, therefore, that the State law and/or the Investment Policy will not be amended in the future to allow for investments which are currently not permitted under such State law or the Investment Policy, or that the objectives of the City with respect to investments will not change. All investments, including those authorized by law from time to time for investments by public agencies, contain a certain degree of risk. Such risks include, but are not limited to, a lower rate of return than expected and loss or delayed receipt of principal. The occurrence of these events with respect amounts held by the City could have a material adverse effect on the City’s finances.
Summary of Condensed Operating Results and Fund Net Position Information A summary of operating results and condensed statement of fund net position for the City’s Electric Utility Fund for the five Fiscal Years ended June 30, 2021 through June 30, 2025 is shown in the following tables. The information for the Fiscal Years ended June 30, 2021 through June 30, 2025 was prepared by the City on the basis of its audited financial information for such Fiscal Years. The following table also sets forth debt service coverage ratios with respect to the City’s outstanding Parity Obligations for the years indicated. See also “– Cash Reserves” above. [Remainder of page intentionally left blank.]
Packet Pg. 421 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 49 4909-8297-8690v6/200986-0003
CITY OF REDDING
ELECTRIC UTILITY FUND
SUMMARY OF OPERATING RESULTS
Fiscal Year Ended June 30,
2021 2022 2023 2024 2025
Revenue
Retail Revenue $ 126,419,111 $ 123,439,749 $ 131,400,744 $ 132,448,887 $ 144,112,668 Wholesale Revenue(1) 25,726,030 30,351,930 44,591,721 30,153,666 23,732,890 Misc. Other Income(2) 6,174,975 5,994,359 23,374,061(13) 7,190,474 8,536,730 Total Revenue $ 158,320,116 $ 159,786,038 $ 199,366,526 $ 169,793,027 $ 176,382,288 Operating Expenses(3)
Cost of Power(4) $ 52,810,777 $ 62,709,514 $ 80,993,472 $ 53,212,490 $ 52,835,271 Maintenance Operations
and Administration
M-S-R Payments 4,486,291 4,530,947 321,609 59,560 387,832 TANC Payments 2,740,288 2,361,697 2,604,247 3,656,589 3,707,551 Other Operating Expenses 79,407,830 69,457,550 83,274,523 84,039,379 92,536,694 Add/(Less) OPEB Expenses(5) (737,360) (735,482) (1,136,682) (1,955,260) (2,519,875) Add/(Less) Pension Expense(6) (7,535,001) 6,199,814 18,334 3,791,794 (2,010,656) In Lieu Tax Payment
to General Fund(7) 6,097,590 5,464,000 6,246,800 7,270,600 6,614,200 Total Expenses $ 137,270,415 $ 149,988,040 $ 172,322,303 $ 150,075,152 $ 151,551,016 Net Revenue $ 21,049,701 $ 9,797,998 $ 27,044,223 $ 19,717,875 $ 24,831,272 Available Reserves(8) $ 87,201,242 $ 71,970,574 $ 70,486,678 $ 59,881,615 $ 72,996,573 In Lieu Tax Payment
to General Fund(7) $ 6,097,590 $ 5,464,000 $ 6,246,800 $ 7,270,600 $ 6,614,200 Funds Available for Debt Service $ 114,348,533 $ 87,232,571 $ 103,777,701 $ 86,870,090 $ 104,442,045 Debt Service(9) $ 12,780,320 $ 12,785,570 $ 14,304,520 $ 14,298,520 $ 14,299,520 Remaining Funds(10) $ 101,568,213 $ 74,447,001 $ 89,473,181 $ 72,571,570 $ 90,142,525 Debt Service Coverage(11) 8.95 6.82 7.25 6.08 7.30
Current Debt Service Coverage(12) 1.65 0.77 1.89 1.38 1.74 __________________
(1) Primarily represents spot market sales of both electricity and natural gas. (2) Developer fees (available for debt service), earnings on Electric Utility Fund balance plus earnings on the Acquisition Fund, Debt Service Fund and the Reserve Fund for the City’s then outstanding Parity Obligations. (3) Excludes depreciation and amortization expenses.
(4) This fluctuates in relation to the volume of wholesale revenue in a given year. (5) The City is not currently pre-funding its OPEB liability. In addition to the portion of the cost of current retiree health insurance premiums allocable to the Electric Utility Department, the operating expenses of the Electric Utility Department for accounting purposes include an amount necessary to reflect the Electric Utility Department’s allocable share of the City’s OPEB liability as of the end of the Fiscal Year. This amount is excluded for calculation of debt service coverage as it is a non-cash item and does not reduce cash available for debt payments. See “– Employees – Retiree Health Benefits” above. (6) Represents adjustment for cash used for operating activities related to pension expense. Certain changes in net pension liabilities are recorded as deferred inflows of resources or deferred outflows of resources depending on the nature of the change.
(7) Represents 1% of installed assets with selected depreciation. Payments are made annually to the City general fund and are reflected as Transfers Out on the Electric Utility Fund Statement of Revenues, Expenses and Changes in Net Assets. (8) This represents the amount of unrestricted funds in the Electric Utility Fund available to pay Maintenance and Operation Costs and/or annual debt service on the outstanding Parity Obligations. Available Reserves are taken into account for purposes of compliance with the rate covenant under the documents pursuant to which the outstanding Parity Obligations were issued.
Available Reserves exclude electric utility funds held in a margin account as posted collateral. See “– Fuel Supply” above. (Footnotes to table continue on the next page)
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(Footnotes to table continued from the prior page)
(9) Reflects installment sale payments under installment sale agreements and debt service on bonds comprising the outstanding Parity Obligations. Interest payments are net of capitalized interest (if any) and final debt service payments made from bond reserve funds (if applicable).
(10) Available for capital expenditures and other lawful purposes. (11) Funds available for Debt Service divided by Debt Service. (12) Net Revenues divided by Debt Service. The documents pursuant to which the outstanding Parity Obligations were issued have no requirement respecting debt service coverage from then current year’s revenues. In certain past years, the City has utilized a portion of its cash reserves to fund part of its annual costs. See “– Cash Reserves” above. (13) Includes $15.9 million in one-time, unanticipated settlement proceeds received in April 2023 from the Central Valley Project Improvement Act (CVPIA) litigation.
Source:City of Redding.
CITY OF REDDING
ELECTRIC UTILITY FUND
CONDENSED STATEMENT OF NET POSITION
Fiscal Year Ending June 30,
2021 2022 2023 2024 2025
Assets:
Net Utility Plant $195,970,192 $194,812,072 $197,472,790 $201,007,916 $209,044,205 Restricted Assets 11 643 12,030 17,827 47,122,825
Current Assets 116,918,989 98,058,068 96,321,693 90,129,737 108,784,076 Non-Current Assets 23,703,977 26,078,543 25,485,377 26,626,743 27,219,480 Deferred Outflow
of Resources 22,901,183 25,070,370 37,354,666 44,609,555 34,196,586 Total Assets $359,494,352 $344,019,696 $356,646,556 $362,391,778 $426,367,172 Liabilities and Equity:
Current Liabilities $ 25,212,444 $ 25,971,831 $ 27,107,920 $ 29,965,643 $ 32,041,631 Long Term Liabilities 85,738,547 67,014,428 97,399,523 103,158,884 99,252,833 Retained Earnings(1) 133,516,316 130,373,590 135,612,411 145,811,761 155,136,165 Long Term Debt 114,216,448 103,408,368 94,995,093 82,417,528 138,662,977 Deferred Inflows
of Resources 810,597 17,251,479 1,531,609 1,037,962 1,273,566 Total Liabilities
and Equity $359,494,352 $344,019,696 $356,646,556 $362,391,778 $426,367,172 __________________
(1) Retained Earnings include contributed capital which represents improvements built by developers at no cost to the Electric System and amounts contributed by other municipal departments.
Source: City of Redding Finance Department.
Management’s Discussion of Summary of Fiscal Year 2024-25 Operating Results As reflected in the table above entitled “Summary of Operating Results,” in Fiscal Year 2025, Electric System retail sales revenues were approximately $144.1 million, representing an increase of approximately $11.7 million, as compared to the prior year. This reflects a stable retail customer base and the 4.0% rate increase effective on January 1, 2025. Wholesale sales revenues declined by approximately $6.4 million (approximately 21.3%). Total expenses increased by approximately $1.5 million (approximately 1%). Overall, Available Reserves of the electric utility increased by approximately $13.1 million from $59.9 million as of June 30, 2024 to $73 million as of June 30, 2025. The increase of approximately $13.1 million in the electric utility’s aggregate Available Reserves from June 30, 2024, to June 30, 2025, was primarily due to reimbursement of previously incurred capital expenditures with Bond Packet Pg. 423 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 51 4909-8297-8690v6/200986-0003
proceeds. “Available Reserves” as defined in the indentures and installment sale agreements relating to the outstanding Parity Obligations include, among other things, customer service deposits and reserves, public benefits program funds, the power plant maintenance fund, and greenhouse gas allowance receipts.
Litigation Affecting the Electric System
At any given time, including the present, there are certain other claims and disputes, including those currently in litigation, that arise in the normal course of the Electric Utility Department’s activities.
Such matters could, if determined adversely to the City, affect expenditures by the Electric Utility Department, and in some cases, its Electric Revenues. The management of the Electric Utility Department and the Redding City Attorney are of the opinion that no pending actions are likely to have a material adverse effect on the City’s ability to make the payments due in connection with the 2026 Bonds. See also “LITIGATION.”
In addition, from time-to-time, there are ongoing proceedings that involve projects in which the City has an interest and which comprise a portion of the current resource portfolio of the City’s Electric Utility. Although the City is generally not a party to such litigation, the outcome of such proceedings may impact the costs and operations of the affected project. The City is not aware of any such presently ongoing proceedings that, if determined adversely, would be expected to materially adversely affect the financial position or operations of the Electric Utility.
RATE REGULATION
The City sets rates, fees and charges for electric service. The authority of the City to impose and collect rates and charges for electric power and energy sold and delivered is not subject to the general regulatory jurisdiction of the California Public Utilities Commission (the “CPUC”), and currently neither the CPUC nor any other regulatory authority of the State of California nor FERC approves such rates and charges. It is possible that future legislative and/or regulatory changes could subject the rates and/or service area of the City to the jurisdiction of the CPUC or to other limitations or requirements. See also “CONSTITUTIONAL LIMITATIONS IN CALIFORNIA ON TAXES AND FEES” for a discussion of certain voter-approved constitutional measures affecting the imposition of fees and charges by governmental agencies in the State.
FERC potentially could assert jurisdiction over rates of licensees of hydroelectric projects and customers of such licensees under Part I of the Federal Power Act, although it as a practical matter has not exercised or sought to exercise such jurisdiction to modify rates that would legitimately be charged. Even if it did assert such jurisdiction, the City’s small hydroelectric project represents only approximately one percent of the available capacity of the City’s total power supply resources.
Under provisions of the Federal Power Act, FERC has the authority, under certain circumstances and pursuant to certain procedures, to order certain utilities (municipal, distribution cooperative or otherwise) to provide transmission access to others at FERC-approved rates. See “CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY.”
The CEC is authorized to evaluate rate policies for electric energy as related to the goals of the Energy Resources Conservation and Development Act and to make recommendations to the Governor, the Legislature and local, publicly-owned electric utilities (“POUs”).
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CERTAIN FACTORS AFFECTING THE ELECTRIC UTILITY INDUSTRY The following discussion of legislative, regulatory and other factors affecting the electric utility industry should be considered when evaluating the Electric System and considering an investment in the 2026 Bonds. This discussion does not purport to be comprehensive or definitive, and these matters are subject to change subsequent to the date hereof. The electric industry has historically been subject to continuing legislative and administrative reform. The City cannot predict at this time whether any additional legislation or rules will be enacted which will affect the Electric System’s finances or operations, but the impacts could be significant. Extensive information on the electric utility industry is available from the legislative and regulatory bodies and other sources in the public domain, and potential purchasers of the 2026 Bonds should obtain and review such information. Such information is not incorporated herein by reference.
The election of new administrations, including the President of the United States, could also impact substantially the current environmental standards and regulations and other matters described herein. For example, upon taking office in January 2025, President Trump issued a series of executive orders affecting executive actions and policies implemented by the prior administration. One such executive order revoked a number of executive actions taken by the Biden administration, including revoking certain executive orders of the Biden administration relating to climate change and clean energy, requiring federal agencies to review all federal government actions taken pursuant to the revoked orders and to take necessary steps to rescind, replace or amend such actions. In addition, the President issued a separate executive order directing the heads of all federal agencies to review all agency actions affecting the development of domestic energy resources, such as oil, natural gas, coal, hydropower, biofuels, critical mineral, and nuclear energy, and within 30 days of identifying any agency action that unduly burdens the production of domestic energy resources, to develop and begin action plans to rescind or revise the agency actions. Further, the agencies were directed to notify the Attorney General so that appropriate action may be taken in any pending litigation, including the request of a stay, related to the identified agency action. A number of legislative, regulatory and other actions have been taken by federal agencies pursuant to such executive orders. Certain of these actions have been the subject of judicial challenges. The ultimate outcome of these and any other executive orders that the President may issue, or other actions Congress or any federal agencies may take, relating to federal energy policy is not yet known. See also “– Federal Energy and Environmental Policies and Legislation – Inflation Reduction Act” and “– Changing Laws and Requirements Generally.”
Federal Energy and Environmental Policies and Legislation Energy Policy Act of 2005. Although the City is exempt from most federal rate regulation pursuant to Section 201(f) of the Federal Power Act (see “RATE REGULATION”), EPAct 2005 imposed specific exceptions. In particular, FERC was given authority over the behavior of market participants.
Under FERC’s authority it can impose penalties on any seller for using a manipulative or deceptive device, including market manipulation, in connection with the purchase or sale of energy or of transmission service. The Commodity Futures Trading Commission (“CFTC”) also has jurisdiction to prohibit certain types of market manipulation or deceptive claims under the Commodity Exchange Act.
EPAct 2005 authorized FERC to issue permits to construct or modify transmission facilities located in a national interest electric transmission corridor if FERC determines that the statutory conditions are met. EPAct 2005 also required the creation of an electric reliability organization (“ERO”) to establish and enforce, under FERC supervision, mandatory Reliability Standards to increase system reliability and minimize blackouts. The Reliability Standards apply to users, owners and operators of the Bulk-Power System, as more specifically set forth in each Reliability Standard. In February 2006, FERC issued Order 672, which certified NERC as the ERO. Many Reliability Standards have since been Packet Pg. 425 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 53 4909-8297-8690v6/200986-0003
approved by FERC. Such Reliability Standards pertain not only to the planning, operations, and maintenance of Bulk-Power System facilities, but also to cyber and physical security of systems that could affect the reliable operation of the electric grid. The Reliability Standards are frequently being amended to address emerging reliability issues.
The ERO or the entities to which NERC has delegated enforcement authority through an agreement approved by FERC (“Regional Entities”), such as the WECC, may enforce the Reliability Standards, subject to FERC oversight, or FERC may independently enforce them. Potential monetary sanctions include fines in excess of $1 million per violation per day. FERC Order 693 further provided the ERO and Regional Entities with the discretion necessary to assess penalties for such violations, while also having discretion to calculate a penalty without collecting the penalty if circumstances warrant.
Federal Regulation of Transmission Access. EPAct 2005 authorizes FERC to compel “open access” to the transmission systems of certain utilities that are not generally regulated by FERC, including municipal utilities if the utility sells more than four million MWhs of electricity per year. Under open access, a transmission provider must allow all customers to use the system under standardized rates, terms and conditions of service.
FERC Order No. 888 requires the provision of open access transmission services on a nondiscriminatory basis by all “jurisdictional utilities” (which, by definition, does not include municipal entities like the City) by requiring all such utilities to file Open Access Transmission Tariffs (OATTs, as defined above). Order No. 888 also requires “non-jurisdictional utilities” (which, by definition, does include the City) that purchase transmission services from a jurisdictional utility under an open access tariff and that owns or controls transmission facilities to provide open access service to the jurisdictional utility under terms that are comparable to the service that the non-jurisdictional utility provides itself.
Section 211A of the EPAct 2005 authorizes, but does not require, FERC to order unregulated transmission utilities to provide transmission services. Specifically, FERC may require an unregulated transmitting utility to provide access to their transmission facilities (1) at rates that are comparable to those that the unregulated transmitting utility charges to itself; and (2) on terms and conditions (not relating to rates) that are comparable to those under which the unregulated transmitting utility provides transmission services to itself that are not unduly discriminatory or preferential.
On February 16, 2007, FERC issued Order 890, which concluded that reform of its pro forma OATT was necessary to reduce the potential for undue discrimination and provide clarity in the obligations of transmission providers and customers. Significantly, in Order 890 FERC stated that it will implement its authority under Section 211A with respect to unregulated transmitting utilities on a caseby-case basis and retain the current reciprocity provisions.
On July 21, 2011, FERC issued Order 1000, which among other things requires public utility (jurisdictional) transmission providers to participate in a regional transmission planning process that produces a regional transmission plan and that incorporates a regional and inter-regional cost allocation methodology. Further, FERC states that it has the authority to allocate costs to beneficiaries of transmission services, even in the absence of a contractual relationship between the owner of the transmission facilities and the beneficiary. Under EPAct 2005, FERC may not require municipal utilities to join regional transmission organizations, in which participating utilities allow an independent entity to oversee operation of the utilities’ transmission facilities. FERC has stated, however, that FERC expects such utilities to participate in the regional processes for transmission planning and that FERC will pursue associated complaints against such utilities on a case-by-case basis.
On May 13, 2024, FERC issued Order 1920 to reform the planning of the nation’s transmission system as well as the allocation of costs for new transmission projects. Order 1920, among other things, Packet Pg. 426 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 54 4909-8297-8690v6/200986-0003
requires public utility (jurisdictional) transmission providers to conduct and periodically update long-term regional transmission planning to anticipate future needs, consider a broad set of benefits when planning new facilities, identify opportunities to modify in-kind replacement of existing transmission facilities to increase their transfer capability, propose methods of cost allocation to pay for selected long-term regional transmission facilities, and increase transparency regarding local transmission planning information. Order 1920 expands the role of states throughout the process of planning, selecting and determining how to pay for new transmission facilities. On November 21, 2024, FERC issued Order No. 1920-A, revising its original Order 1920 in response to numerous requests for rehearing and clarification.
The revisions to Order 1920 provide state regulators with a larger role in the long-term regional transmission planning process, particularly in shaping scenario development and cost allocation, by requiring transmission providers to include state input about how future scenarios in the long-term regional transmission planning will be developed and to include any state-agreed cost allocation proposals in their compliance plans. The revised rule also eliminates the requirement for transmission planners to use several recommended economic and reliability costs factors when evaluating potential long-term transmission projects. The City is evaluating the implications of Order 1920 with respect to the operations of the Electric System.
Federal Policy on Cybersecurity. In February 2013, then-President Obama issued Executive Order 13636 “Improving Critical Infrastructure Cybersecurity” (the “Cybersecurity Order”). Among other things, the Cybersecurity Order called for improved information sharing and processing of security clearances for owners and operators of critical infrastructure. The Cybersecurity Order further required the Secretary of Commerce to direct the National Institute of Standards and Technology (“NIST”) to lead the development of a framework (“Framework”) to reduce cyber risks to critical infrastructure. The voluntary Framework continues to be updated and improved as industry provides feedback on implementation. The City will continue to monitor developments in order to help ensure that the Framework continues to recognize the existing cybersecurity efforts in the electric sector, and does not undermine them by creating duplicative or inconsistent processes.
The Cybersecurity Information Sharing Act of 2015 was signed into law in December 2015. It created an industry-supported, voluntary cybersecurity information sharing program to facilitate the secure sharing of cyber-related threat information among both public and private sector entities. The City participates in sharing and receiving information about cybersecurity threats in real time through several hubs, including the Electricity Information Sharing and Analysis Center (E-ISAC) and the National Cybersecurity and Communication Integration Center, as tools to actively manage risk related to potential cyber intrusion. The Cybersecurity Information Sharing Act expired on September 30, 2025, and efforts to reauthorize it have not yet resulted in an extension or reauthorization.
Regulatory Actions Under the Clean Air Act. The United States Environmental Protection Agency (the “EPA”) regulates greenhouse gas (“GHG”) emissions under existing law by imposing monitoring and reporting requirements, and through its permitting programs. Like other air pollutants, GHGs are regulated under the Clean Air Act through the Prevention of Significant Deterioration (“PSD”) Permit Program and the Title V Permit Program. A PSD permit is required before commencement of construction of new major stationary sources or major modifications of a major stationary source and requires best available control technologies (“BACT”) to control emissions at a facility. Title V permits are operating permits for major sources that consolidate all Clean Air Act requirements (arising, for example, under the Acid Rain, New Source Performance Standards, National Emission Standards for Hazardous Air Pollutants, and/or PSD programs) into a single document and the permit process provides for review of the documents by the EPA, state agencies and the public. GHGs from major natural gasfired facilities are regulated under both permitting programs through performance standards imposing efficiency and emissions standards.
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In May 2023, the EPA proposed new regulations under the Clean Air Act that would establish greenhouse gas emission limits, based on pollution control technology or lower-carbon fuels, for new gas plants, existing gas plants, and existing coal plants, as specified. In February 2024, the EPA announced that it would remove the elements that would have applied to existing natural gas-fired power plants from the final version of the rule. Instead, the EPA stated that it would commence a new rulemaking process that would apply to existing natural gas-fired plants and regulate additional pollutants. In April 2024, the EPA finalized the rule establishing carbon dioxide (“CO2”) emissions standards and guidelines for newly built and reconstructed stationary combustion turbines (generally natural gas-fired) and existing and modified fossil fuel-fired steam generating units (generally coal-fired). The final rule identified a standard of performance reflecting the application of best systems for emissions reduction (BSER), taking into account costs, energy requirements and other statutory factors. Under the final rule, emissions standards and guidelines were established for different subcategories of power plants according to unit characteristics such as their generating technology, capacity, level of operations, and anticipated remaining operational life of the unit.
In June 2025, the EPA proposed to repeal all GHG emissions standards for fossil-fuel fired power plants under Section 111 of the Clean Air Act, relating to emissions from new and existing stationary sources of air pollution. The EPA is also proposing, as an alternative, to repeal a narrower set of requirements that include the emission guidelines for existing fossil fuel-fired steam generating units, the carbon capture and sequestration/storage (“CCS”)-based standards for coal-fired steam generating units undertaking a large modification, and the CCS-based standards for new base load stationary combustion turbines.
In February 2026, the EPA issued a final rule rescinding a greenhouse gas endangerment finding as it applies to regulating emissions from new motor vehicles and new motor vehicle engines.
This is expected to result in the EPA removing greenhouse gas regulations for light- medium-, and heavy-duty on-highway vehicles. The repeal of such endangerment finding itself does not directly impact existing regulations. Changing existing regulations will require separate actions. However, it is widely expected that the EPA’s action will trigger multiple lawsuits regarding both the finding itself and air emissions regulations related to it. These issues are expected to be litigated for some time. The EPA’s action does not apply directly to stationary sources, including oil and gas facilities and power plants. While the action is targeted at vehicles (i.e., mobile sources), this EPA action could have broader ramifications in the future, including impacts related to how and when the EPA does or does not regulate other sources of greenhouse gases.
Inflation Reduction Act. On August 16, 2022, then President Biden signed the Inflation Reduction Act of 2022 (the “IRA”). The IRA introduced a large amount of funding and grants for governmental and non-profit organizations. Among the most significant energy-related grants are grants for “zero-emissions technologies” and other GHG reduction activities as determined the EPA. Pursuant to the IRA, public power utilities and other tax-exempt entities are also given access to refundable direct payment tax credits. Among the energy-related tax credits that may be available if certain requirements are met are a clean hydrogen production tax credit, a biogas and energy storage credit, and enhancements to the credit for carbon capture. The IRA also expanded and extended the renewable electricity production tax credit and the investment tax credits for renewable energy sources.
On July 4, 2025, the President signed the “One Big Beautiful Bill Act,” that is expected to significantly impact the IRA’s clean energy tax credits, effectively accelerating their repeal or significantly restricting them, especially those related to electric vehicles and clean electricity production.
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State Legislation and Regulatory Proceedings
A number of bills affecting the electric utility industry have been introduced or enacted by the California Legislature in recent years. In general, these bills reflect California climate policy developments by regulating GHG emissions and providing for greater investment in energy efficiency and environmentally friendly generation and storage alternatives, principally through more stringent RPS requirements and more aggressive emissions reduction programs to combat the effects of climate change.
Legislation enacted in recent years has also focused on addressing issues relating to wildfire risks and occurrences in California, including imposing certain requirements on electric utilities in connection with planning for and mitigating such occurrences and risks. Set forth below is a brief summary of certain of these bills and regulatory proceedings.
California Climate Program. In September 2006, then-Governor Arnold Schwarzenegger signed into law Assembly Bill 32, the California Global Warming Solutions Act of 2006 (“AB 32” or the “Global Warming Solutions Act”). This law, which became effective on January 1, 2007, required CARB to adopt enforceable GHG emission limits and emission reduction measures in order to reduce GHG emissions from within the State to 1990 levels by 2020. In September 2016, then-Governor Jerry Brown signed into law Senate Bill 32 (“SB 32”), an amendment to the Global Warming Solutions Act, that requires CARB to take such actions to ensure that statewide GHG emissions from within the State are reduced to at least 40% below 1990 levels by 2030.
SB 350, the Clean Energy and Pollution Reduction Act of 2015, signed into law by thenGovernor Brown in October 2015, among other things, requires CARB, in consultation with the CPUC and the CEC, to establish 2030 GHG emission targets for each electric utility in the State. SB 350 was superseded by SB 100, adopted in 2018, which set a 100% zero-carbon by 2045 requirement and accelerated RPS targets to 50% by 2025 and 60% by 2030. At present, these targets are non-binding, and primarily intended to help the State measure progress toward the 2030 statewide goal outlined in SB 32.
The targets, however, are an input to the development of the Integrated Resource Plans that are required of the State’s utilities with over 700 GWh annual retail sales, which includes the City. See “– California Renewables Portfolio Standard” below.
The Global Warming Solutions Act established an annual mandatory reporting requirement for all investor-owned utilities (“IOUs”), POUs, and other load-serving entities (electric utilities providing energy to end-use customers) to inventory and report GHG emissions to CARB. It required CARB to adopt regulations for significant GHG emission sources and gave CARB the authority to enforce such regulations beginning in 2012. The City is complying with the applicable reporting requirements under the Global Warming Solutions Act.
In September 2022, Governor Newsom signed into law Assembly Bill 1279 (“AB 1279”), which became effective on January 1, 2023, and established additional GHG emission reduction goals. AB 1279 declares the policy of the State both to achieve net-zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emissions thereafter, and to ensure that by 2045, Statewide anthropogenic GHG emissions are reduced to at least 85% below the 1990 levels. Under AB 1279, “net zero GHG emissions” means emissions of GHGs to the atmosphere are balanced by removals of GHG emissions over a period of time. The bill directs CARB to ensure that its scoping plan identifies and recommends measures to achieve these policy goals. The State Legislative Analyst’s Office is required to conduct an independent assessment of progress toward the bill’s objectives every two years and to make its findings available to the public.
In September 2022, Senate Bill 1020 (“SB 1020”), the Clean Energy, Jobs, and Affordability Act of 2022, was signed into law. Under SB 100, it is the policy of the state that eligible renewable energy Packet Pg. 429 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 57 4909-8297-8690v6/200986-0003
resources and zero-carbon resources supply 100% of all retail sales of electricity to California end-use customers and 100% of electricity procured to serve all state agencies by December 31, 2045. SB 1020 revised the state policy to provide that eligible renewable energy resources and zero-carbon resources supply 90% of all retail sales of electricity to California end-use customers by December 31, 2035, 95% of by December 31, 2040, 100% by December 31, 2045, and 100% of electricity procured to serve all state agencies by December 31, 2035, as specified.
Cap-and-Trade Regulations. CARB has implemented the Global Warming Solutions Act through a series of regulations (collectively referred to as the “Cap-and-Trade Regulations”) that imposed declining aggregate emissions limitations on entities in California that meet minimum reporting thresholds. The Cap-and-Trade Regulations require all regulated entities, including the City, to report annual GHG emissions and to obtain and submit to CARB compliance instruments (allowances and/or offsets) that represent GHG emissions related to its industrial processes within the State. For electric utilities, this includes generation and GHG emissions associated with imported electricity from out-ofstate resources. Like other electric utilities, the City receives an administrative allocation of allowances for compliance. Entities that emit GHGs at levels above those for which they receive administrative allocations, if any, must purchase the additional allowances they require at quarterly CARB auctions or from other covered entities with surplus allowances.
In July 2017, then-Governor Brown signed into law Assembly Bill 398 (“AB 398”), extending the Cap-and-Trade Regulations from 2021 to 2030. The bill passed both chambers with a 2/3 supermajority vote, which protects the legislation from certain legal challenges. Under AB 398, CARB was directed to address the following: establish a price ceiling, offer non-tradeable allowances at two price containment points below the price ceiling, transfer current vintages unsold for more than 24 months to the allowance price containment reserve, evaluate and address allowance over-allocation concerns, set industry assistance factors for allowance allocation, and establish allowance banking rules. Under AB 398, CARB was directed to include cost containment provisions to keep allowance prices from rising too high and pushing business expansion outside of the state (referred to as “leakage”). AB 398 was passed in conjunction with AB 617, which strengthens the monitoring of criteria air pollutants and toxic air contaminants in local communities. Amendments to the Cap-and-Trade Regulations to reflect the requirements of AB 398 were adopted by CARB and went into effect on April 1, 2019.
In September 2025, AB 1207 was signed into law. AB 1207 reauthorizes and extends California’s cap-and-trade program from 2030 to 2045 (which program is to be now referred to as the California Capand-Invest Program pursuant to the provisions of AB 1207).
At this time, the City is unable to predict the full impact of the Cap-and-Trade Regulations over the long-term on the City’s Electric System, on the electric utility industry generally, or whether any additional changes to the adopted program will be made. Since the advent of the cap-and-trade program in 2012, regulations by CARB have provided the electric sector, including the City on behalf of its ratepayers, with sufficient allocated GHG allowances or credits to cover existing operations in meeting retail load obligations. The City may bank allocated allowances in its compliance account to satisfy a portion of its ongoing compliance obligations. The City can buy or sell allowances in the quarterly auctions or on the bilateral market to meet its additional compliance obligations. Currently, the City is sufficiently positioned for compliance.
CARB is in the process of developing amendments to the Cap-and-Trade Regulations. The scope of the potential amendments under consideration by CARB includes, among other things, using an updated integrated energy forecast to adjust (reduce) allowance allocations through 2030, reducing the total number of budgeted allowances starting in 2027, and requiring POUs to consign all allocated allowances to auction (similar to investor-owned utilities). The City could be adversely affected if its Packet Pg. 430 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 58 4909-8297-8690v6/200986-0003
GHG emissions exceed its allocated allowances, which would require additional compliance instruments to be purchased from the market to meet retail load compliance obligations. Comments on the proposal are due March 9, 2026, after which it is anticipated that there will be additional “15-day changes” proposed by CARB, before a targeted May 28, 2026 hearing to consider the proposal. CARB is aiming to finalize the rulemaking by September 2026, in time to influence allowance allocation for 2027. The City is monitoring developments in connection with this proposed rulemaking. Although the regulations from CARB are not yet finalized, the current proposal suggests a potential impact of approximately $2.4 million through 2030.
GHG Emissions Performance Standard and Financial Commitment Limits. Senate Bill 1368 (“SB 1368”) became effective as law on January 1, 2007. SB 1368 provided for an emission performance standard (“EPS”) restricting new investments in baseload electric generating resources exceeding a specified rate of GHG emissions. SB 1368 allows the CEC to establish a regulatory framework to enforce the EPS for POUs. Pursuant to SB 1368, the CEC adopted a GHG EPS for electric generating facilities of 1,100 pounds of CO2 per MWh for “covered procurements” by POUs. SB 1368 also prohibits POUs from making any “long-term financial commitment” in connection with “baseload generation” that does not satisfy the EPS. Generally, a “long-term financial commitment” is any new or renewed power purchase agreement with a term of five years or more, the purchase of an interest in a new power plant, or any investment (other than routine maintenance) in an existing power plant that extends the life of the plant by more than five years or results in an increase in its rated capacity. “Baseload generation” means a power plant that is intended to operate at an annualized capacity factor of 60% or more.
As modified, the EPS regulations require a POU to post a public meeting notice at which its governing board will consider any expenditure over $2.5 million to meet environmental regulatory requirements at a non-EPS-compliant baseload facility. In addition, each POU is required to file an annual notice identifying all investments over $2.5 million that it anticipates making during the subsequent 12 months on non-EPS-compliant baseload facilities to comply with environmental regulatory requirements.
This requirement is waived for any POU that has entered into a binding agreement to divest within five years of all baseload facilities exceeding the EPS. CEC staff has confirmed that the $2.5 million threshold applies to an individual investment by each utility, and not the combined investment of all participants in a project.
Any future procurement or investment by the City in a baseload generating resource of greater than 10 MW or with a term of five years or more (or extending the life of an existing plant by more than five years) will be subject to the requirements of SB 1368.
Energy Procurement and Efficiency Reporting. Senate Bill 1037 (“SB 1037”) was signed into law by then-Governor Schwarzenegger in September 2005. It requires that each POU, including the City, first acquire all available energy efficiency, demand reduction, and renewable resources that are costeffective, reliable, and feasible prior to procuring new energy generation resources. SB 1037 also requires each POU to report annually to its customers and to the CEC its investment in energy efficiency and demand reduction programs. The City is complying with these ongoing reporting requirements.
Further, Assembly Bill 2021 (“AB 2021”), signed into law by then-Governor Schwarzenegger in September 2006, requires that POUs establish, report, and explain the basis of the annual energy efficiency and demand reduction targets by June 1, 2007, and every three years thereafter for a ten-year horizon. A subsequent amendment, Assembly Bill 2227, extended the reporting timeframe from three to four years. The City is complying with these ongoing reporting requirements. The information obtained from the POUs is being used by the CEC to present progress made by the State to double energy efficiency savings in electricity and natural gas final end uses by 2030, to the extent doing so is costeffective, feasible, and does not adversely impact public health and safety, as prescribed in SB 350.
Packet Pg. 431 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 59 4909-8297-8690v6/200986-0003
California Renewables Portfolio Standard. California’s legislature and executive branch have been active in promoting increasingly stringent renewable energy procurement requirements since 2002.
Early efforts established a renewables portfolio standard (RPS) of 20% of renewable electricity generation by 2017. Since then, both legislative and executive branch initiatives have raised that standard in multiple phases.
SBX1-2, the California Renewable Energy Resources Act, was signed into law by then-Governor Brown in April 2011. SBX1-2 required each POU to adopt and implement a renewable energy resource procurement plan and establish targets for specified compliance periods for the procurement of at least the following amounts of electricity products from eligible renewable energy resources (which could include RECs) as a proportion of total kilowatt hours sold to the utility’s retail end-use customers: (i) over the 2011-2013 compliance period, an average of 20% of retail sales from January 1, 2011 to December 31, 2013, inclusive; (ii) over the 2014-2016 compliance period, a total equal to 20% of 2014 retail sales, 20% of 2015 retail sales, and 25% of 2016 retail sales; (iii) over the 2017-2020 compliance period, a total equal to 27% of 2017 retail sales, 29% of 2018 retail sales, 31% of 2019 retail sales, and 33% of 2020 retail sales; and (iv) for 2021 and each subsequent year, 33% of retail sales for the applicable year. The governing boards of POUs are responsible for implementing the requirements of SBX1-2, rather than the CPUC, as is the case for the IOUs. In addition, the CEC was given certain enforcement authority for POUs and CARB was given the authority to set penalties. The CEC developed detailed rules to implement SBX1-2, and has adopted regulations for the enforcement of the RPS program requirements for POUs, which regulations have been subsequently amended from time to time.
SB 350, the Clean Energy and Pollution Reduction Act of 2015, as enacted, establishes an RPS target of 50% by December 31, 2030, for the amount of electricity generated and sold to retail customers from eligible renewable energy resources for retail sellers and POUs, including interim targets of (i) 40% of retail sales from eligible renewable energy resources by December 31, 2024; (ii) 45% of retail sales from eligible renewable energy resources by December 31, 2027; and (iii) 50% of retail sales from eligible renewable energy resources by December 31, 2030.
SB 100, signed into law in 2018, supersedes and builds upon the goals of SB 350 by raising the RPS target to 60% by December 31, 2030, and establishes a new policy that all electricity in California be carbon-free by 2045. This policy effectively accelerates and expands the renewable energy targets, requiring retail sellers and POUs to achieve 60% by December 31, 2030. The passage of SB 100 significantly increases the compliance requirements under the RPS and reinforces the long-term commitment to achieving a carbon-free electricity grid statewide.
SB 350 requires each retail seller of electricity (including IOUs, most POUs above a certain size threshold, community choice aggregators, and energy service providers) to provide a renewable energy procurement plan on an annual basis, and all POUs with demand greater than 700 gigawatt hours to develop an integrated resource plan (“IRP”) at least once every five years, commencing no later than January 1, 2019. The City is subject to this requirement. As required in the statute, all IRPs are to be submitted to the CEC, including information outlined in the CEC’s POU IRP Guidelines. The City filed its first IRP with the CEC in April 2019. In accordance with SB 350, the City’s 2024 IRP was approved by the City Council in November 2023 and filed with the CEC by April 30, 2024. The CEC formally approved the City’s 2024 IRP at a public hearing in May 2025.
In December 2020, the CEC adopted regulations to update its RPS enforcement procedures for POUs, including to update regulations amended by both SB 350 and SB 100, among other enacted bills.
This includes implementing a provision relating to the long-term procurement of renewable resources which requires, beginning January 1, 2021, that at least 65% of renewable procurement must be for a duration of 10 years or more. The regulations implement the new RPS procurement requirements for the Packet Pg. 432 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 60 4909-8297-8690v6/200986-0003
compliance periods between 2021 and 2030, establish soft procurement targets for the intervening years of the compliance periods to demonstrate reasonable progress in meeting the RPS procurement target for the compliance periods, and establish three-year compliance periods beginning after 2030. The regulations also define requirements for 10-year procurement contracts for purposes of satisfying the long-term procurement requirement.
Senate Bill 1020 (“SB 1020”), the Clean Energy, Jobs, and Affordability Act of 2022, was signed into law by Governor Newsom in September 2022 and became effective on January 1, 2023. SB 1020 revises SB 100’s State policy on eligible renewable energy resources and zero-carbon resources supply, and establishes that it is the policy of the State that eligible renewable energy resources and zero-carbon resources supply (i) 90% of all retail sales of electricity to California end-use customers by December 31, 2035, (ii) 95% of all retail sales of electricity to California end-use customers by December 31, 2040, (iii) 100% of all retail sales of electricity to California end-use customers by December 31, 2045, and (iv) 100% of electricity procured to serve all state agencies by December 31, 2035.
Legislation Relating to Wildfires; Related Risks. Senate Bill 1028 (“SB 1028”) was signed into law by then-Governor Brown in September 2016. SB 1028 requires that each POU and each electric cooperative in the State construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of catastrophic wildfire posed by those electrical lines and equipment. SB 1028 required the governing board of each POU to determine, based on historical fire data and local conditions, and in consultation with the fire departments or other entities responsible for the control of wildfires within the geographical area where the utility’s overhead electrical lines and equipment are located, whether any portion of that geographical area has a significant risk of wildfire resulting from those electrical lines and equipment, and if so, to present for its governing board approval wildfire mitigation measures the utility intends to undertake to minimize the risk of its overhead electrical lines and equipment causing a catastrophic wildfire.
SB 901 was signed into law by then-Governor Brown in September 2018. SB 901 amends certain provisions of SB 1028 requiring POUs and electric cooperatives to prepare wildfire mitigation measures if the utilities’ overhead electrical lines and equipment are located in an area that has a significant risk of wildfire resulting from those electrical lines and equipment. Under SB 901, each POU or electric cooperative is required to prepare before January 1, 2020 and annually thereafter, a wildfire mitigation plan. SB 901 requires specified information and elements to be considered as necessary, at minimum, in the wildfire mitigation plan. The POU or electric cooperative is required to present each wildfire mitigation plan in an appropriately noticed public meeting, and to accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties. In addition, SB 901 requires the POU or electric cooperative to contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan. The report of the independent evaluator is to be made available to the public and to be presented at a public meeting of the POU’s governing board. In accordance with the requirements of SB 901 and subsequent legislation (AB 1054 discussed below), the City’s initial wildfire mitigation plan was approved by the City Council in December 2019. The review and assessment of the City’s wildfire mitigation plan by an independent evaluator was subsequently completed. In accordance with the requirements of SB 901, the City’s wildfire mitigation plan is updated annually, with comprehensive revisions and independent evaluator review occurring every three years.
The City’s wildfire mitigation plan was most recently submitted to the City Council in May of 2024 for approval and submitted to the Wildfire Advisory Board in July of 2024. See also “THE ELECTRIC SYSTEM – Wildfire Mitigation Measures.”
Assembly Bill 1054 (“AB 1054”) was signed into law by Governor Newsom in July 2019. AB 1054 establishes a Wildfire Fund for IOUs to facilitate payment of eligible, uninsured third-party damage Packet Pg. 433 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 61 4909-8297-8690v6/200986-0003
claims resulting from future catastrophic wildfires. Participation in the Wildfire Fund is exclusive to IOUs. Each of the major IOUs in California are now participating in the in the Wildfire Fund. POUs, such as the City, are not eligible to participate in or receive funding for wildfire claims from the Wildfire Fund.
AB 1054 expands on the existing requirements for POUs established under SB 901 for wildfire mitigation plans. AB 1054 requires each POU, by July 1 of each year, to submit its wildfire mitigation plan to the then-newly created Wildfire Advisory Board for review and comment. Under AB 1054, the Wildfire Advisory Board is required to provide comments and an advisory opinion to each POU regarding the content and sufficiency of its plan and to make recommendations on the mitigation of wildfire risks. AB 1054 requires each POU to comprehensively revise its wildfire mitigation plan at least once every three years. The City has prepared and submitted wildfire mitigation plans in accordance with the provisions of SB 901 and AB 1054 as required. SB 254, signed into law by Governor Newsom in September 2025 amends the provisions of AB 1054 to provide that, after January 1, 2026, POUs will instead be required to prepare and submit to the Wildfire Advisory Board wildfire mitigation plans at least once every four years on a schedule to be determined by the Wildfire Advisory Board.
A number of significant wildfires have occurred in California during the last several years. Under the doctrine of inverse condemnation (a legal concept that entitles property owners to just compensation if their private property is damaged by a public use), California courts have imposed liability on utilities in legal actions brought by property holders for damages, where the inherent risks in the utility’s infrastructure, as deliberately designed, constructed or maintained, are determined to be a substantial cause of damage to the property. Thus, if the inherent risks associated with the facilities of a utility, such as its electric distribution and transmission lines, are determined to be the substantial cause of the plaintiff’s damages, and the doctrine of inverse condemnation applies, the utility could be liable without having been found negligent. In August 2019, in its decision in the case of City of Oroville v. Superior Court of Butte County, 7 Cal.5th 1091, 446 P.3d 304 (2019), involving damages related to sewage overflows from a city sewer system, the California Supreme Court held that to succeed on an inverse condemnation claim, a property owner must demonstrate that the property damage was the probable result or necessary effect of an inherent risk associated with the design, construction or maintenance of the relevant public improvement. SB 1028, SB 901 and AB 1054 do not alter the existing legal doctrine relating to utilities’ liability for wildfires. SB 254 requires the California Earthquake Authority, as administrator of the wildfire fund established pursuant to AB 1054, to, on or before April 1, 2026, in consultation with the CPUC and other specified departments and agencies of the State, and with feedback solicited from stakeholders, prepare and submit to the Legislature, and to the Governor, a report that evaluates and sets forth recommendations on new models or approaches that mitigate damage, accelerate recovery, and responsibly and equitably allocate the burdens from natural catastrophes, including catastrophic wildfires, earthquakes, and other natural disasters, across stakeholders, including insurers, communities, homeowners, landowners, governments, electrical corporations, and POUs to complement or replace the fund. How any future legislation or judicial decisions address California’s inverse condemnation doctrine, and liability issues for utilities in the context of wildfires in particular, could be significant for the electric utility industry, including the City.
Impact of California Energy Market Developments on the City. The effect of the developments in the California energy markets described above on the City’s Electric System cannot be fully ascertained at this time. Also, volatility in energy prices in California may return due to a variety of factors that affect both the supply and demand for electric energy in the western United States. These factors include, but are not limited to, the adequacy of generation resources to meet peak demands at all times, the availability and cost of renewable energy, the impact of economy-wide GHG emission legislation and regulations, fuel costs and availability, weather effects on customer demand, the impact of climate change, wildfire mitigation and potential liability cost recovery, insurance costs, transmission congestion, the strength of the economy in California and surrounding states and levels of hydroelectric Packet Pg. 434 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 62 4909-8297-8690v6/200986-0003
generation within the region (including the Pacific Northwest). This price volatility may contribute to greater volatility in the City’s revenues from the sale (and purchase) of electric energy and, therefore, could materially affect the City’s financial condition. The City, individually and/or through joint powers agencies in which it participates, undertakes resource planning and risk management activities and manages its resource portfolio to mitigate such price volatility and spot market rate exposure. See “THE ELECTRIC SYSTEM.”
Changing Laws and Requirements Generally
Electric utilities are subject to continuing environmental regulation. Federal, State and local standards and procedures which regulate the environmental impact of electric utilities are subject to change. These changes may arise from continuing legislative, regulatory and judicial action regarding such standards and procedures. In addition, the election of new administrations, including the President of the United States, could impact substantially the current environmental standards and regulations and other matters described herein. In light of the changing regulatory requirements and standards for electric utilities, there is no assurance that any facilities or projects of the City will remain subject to the laws and regulations currently in effect, will always be in compliance with future laws and regulations or will always be able to obtain all required operating permits. An inability to comply with environmental standards could result in, for example, additional capital expenditures, reduced operating levels or the shutdown of individual units not in compliance. Increased environmental laws and regulations may create certain barriers to new facility development, may require modification of existing facilities and may result in additional costs for affected resources.
In addition, on both the federal and State levels, legislation is introduced frequently addressing domestic energy policies and various environmental matters and impacts relating to energy, including the generation of energy using conventional and unconventional technologies. Issues raised in legislative proposals in recent years have included implementation of energy efficiency and renewable energy standards, addressing transmission planning, siting and cost allocation to support the construction of renewable energy facilities, cybersecurity legislation, climate change and the reduction or elimination of net carbon dioxide emission attributable to the electric grid and financial incentives that could provide grants and credits to municipal utilities to invest in renewable energy infrastructure. Congress has also considered other bills relating to energy supplies and development (such as expedited permitting for natural gas drilling projects, reducing regulatory burdens, climate change and water quality). The City is unable to predict at this time whether any of these or other legislative proposals will be enacted into law or what the impact of any such proposals that may ultimately be enacted will be.
General Economic Conditions
The City’s costs are affected by numerous factors, many of which are economic variables that are beyond its control. Some of the factors in recent years include inflation, supply chain disruptions and delays, labor shortages and rising labor costs, and rising interest rates. More specifically, the rate of inflation increased during certain periods of recent years, increasing the price of fuel and commodities integral to the City’s Electric System operations. In response to rising inflation, the United States Federal Reserve increased interest rates a number of times from 2022 to 2023, which would be expected to result in an increase to the City’s costs of capital so long as inflationary pressures continue. These factors may be further exacerbated by rising labor costs in the United States and global economic and geopolitical crises. Retail energy sales and aggregate levels of energy use can also be affected by general economic conditions. The economy may be impacted (directly or indirectly) by, among other things, fluctuations in business production, consumer prices, or financial markets, unemployment rates, technological advancements, shortages or surpluses in natural resources, climate change and other environmental matters, changes in law (including the enforcement thereof), changes in federal or state policies (including Packet Pg. 435 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 63 4909-8297-8690v6/200986-0003
policies with respect to trade, appropriations, immigration, regulation and energy) and funding priorities, and natural disasters. The occurrence of global, national and/or regional events and changes in general economic conditions on a local, state, and/or national level and their potential impacts are difficult to predict but could negatively impact the Electric System’s operations and finances and/or the economy of its service area. See APPENDIX B – “CERTAIN INFORMATION CONCERNING THE CITY OF REDDING” for general demographic and economic information regarding the City’s service area.
Tariff Uncertainty
Recent changes in federal and international trade policies, including the imposition or adjustment of tariffs on materials such as steel, solar panels, batteries and other building materials and energy-related equipment, have introduced uncertainty into the pricing and availability of key components used in the City’s operations and capital projects. While the City monitors these developments, the future impacts of tariff-related volatility on the City’s costs, procurement schedules, and project economics are uncertain and could be material.
Cybersecurity Risks; Physical Security of the Electric System Physical and cybersecurity are critical concerns for electric utilities as they seek to protect their infrastructure and technological systems from a range of threats. The electric utility infrastructure is complex and consists of multiple components, such as power plants, substations, transmission and distribution lines, and other facilities. The City has policies, processes and procedures in place that outline the access controls and restrictions for its properties.
The City like many other public and private entities and utilities, relies on computer and other digital networks and systems to conduct its operations, including operations of the Electric System. In connection with the use of such technology, the City and the Electric System are potentially subject to multiple cyber threats, including without limitation hacking, viruses, ransomware, malware and other attacks. United States government agencies have in the past issued warnings indicating that critical infrastructure sectors such as electric systems may be specific targets of cybersecurity threats.
Cybersecurity incidents could result from unintentional events, or from deliberate attacks by unauthorized entities or individuals attempting to gain access to the City’s digital networks and systems for the purposes of misappropriating assets or information or causing operational disruption and damage. To mitigate the risk of business operations impact and/or damage from cybersecurity incidents or cyberattacks, the City invests in multiple forms of cybersecurity and operational safeguards. Although the City has a variety of security measures and safeguards in place with respect to the Electric System (as described under “THE ELECTRIC SYSTEM – Cybersecurity Measures” above), no assurances can be given that any existing or additional safety and security measures will prove adequate in the event that cyberattacks or military conflicts or terrorist activities, including cyber terrorism, are directed against the City’s systems technology or the assets of the Electric System. Cyberattacks are becoming more sophisticated and certain cyber incidents, such as surveillance, may remain undetected for an extended period. Attacks directed at critical electric sector operations could damage generation, transmission or distribution assets, cause operational malfunctions and outages, and result in costly recovery and remediation efforts. The costs of security measures or of remedying damage from security breaches could be greater than presently anticipated.
Global Health Emergencies
A pandemic, epidemic or outbreak of an infectious disease can have significant adverse health and financial impacts on global and local economies. For example, beginning in 2020, the COVID-19 pandemic negatively affected economic activity throughout the world, including the United States and the Packet Pg. 436 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 64 4909-8297-8690v6/200986-0003
State of California. The initial impacts of stay-at home orders globally were unprecedented, with commerce, travel, asset values and financial markets experiencing disruptions worldwide. The City’s ability to provide electric service was not impaired as a result of the COVID-19 pandemic. The City’s Electric System is in a federally designated critical infrastructure sector and continued to operate throughout the COVID-19 pandemic. While the COVID-19 pandemic impacted the City in certain respects, the City did not experience a material adverse impact to the Electric System’s operations or its ability to meet its financial obligations as a result of the COVID-19 pandemic. To help mitigate the economic impact of COVID-19 and the related governmental regulations on its customers, the City implemented a suspension of the disconnection of electric services for non-payment of utility bills beginning in March 2020. Normal practices for non-payment resumed in late summer 2021. However, while the declarations of COVID-19 as a public health emergency have been lifted, future pandemics and other widespread public health emergencies can and do arise from time to time. The City cannot predict whether another national or localized outbreak of highly contagious or epidemic disease in the future could negatively impact the Electric System’s operations and finances and/or the economy of its service area.
Other Factors
The electric utility industry in general has been, or in the future may be, affected by a number of other factors which could impact the financial condition and competitiveness of many electric utilities and the level of utilization of generating and transmission facilities. Such factors (a number of which are further discussed elsewhere in the this Official Statement) include, among others, (a) effects of compliance with rapidly changing environmental, safety, licensing, regulatory and legislative requirements other than those described above; (b) changes resulting from conservation and demand-side management programs on the timing and use of electric energy; (c) effects on the integration and reliability of power supply from the increased usage of renewables; (d) changes resulting from a national energy policy; (e) effects of competition from other electric utilities (including increased competition resulting from a movement to allow direct access or expanded community choice aggregation or from mergers, acquisitions, and “strategic alliances” of competing electric and natural gas utilities and from competitors transmitting less expensive electricity from much greater distances over an interconnected system) and new methods of, and new facilities for, producing low-cost electricity; (f) the repeal of certain federal statutes that would have the effect of increasing the competitiveness of many IOUs; (g) increased competition from independent power producers and marketers, brokers and federal power marketing agencies; (h) “self-generation” or “distributed generation” (such as microturbines, fuel cells and solar installations) by industrial and commercial customers and others; (i) issues relating to the ability to issue tax-exempt obligations, including restrictions on the ability to sell to nongovernmental entities electricity from generation projects and transmission service from transmission line projects financed with outstanding tax-exempt obligations; (j) wildfires and potential liabilities of electric utilities in connection therewith; (k) effects of inflation on the operating and maintenance costs of an electric utility and its facilities; (l) changes from projected future load requirements; (m) increases in costs and uncertain availability of capital; (n) shifts in the availability and relative costs of different fuels (including the cost of natural gas); (o) changes in the electric market structure for neighboring electric grids, such as the energy imbalance market operated by the CAISO; (p) sudden and dramatic increases in the price of energy purchased on the open market that may occur in times of high peak demand in an area of the country experiencing such high peak demand, such as has occurred in the past in California; (q) issues relating to risk management procedures and practices with respect to, among other things, the purchase and sale of natural gas, energy and transmission capacity; (r) other legislative changes, voter initiatives, referenda and statewide propositions; (s) effects of the changes in the economy, population and demand of customers within a utility’s service area; (t) effects of possible manipulation of the electric markets; (u) acts of terrorism or cyber-terrorism impacting a utility and/or significant load customers; (v) impacts of a pandemic or the outbreak of another infectious disease impacting the global, national or local Packet Pg. 437 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 65 4909-8297-8690v6/200986-0003
economy or a utility’s service area; or (w) effects of and regulatory responses to climate change; (x) natural disasters or other physical calamities, including, but not limited to, wildfires, earthquakes, droughts, severe weather and floods; and (y) adverse impacts to the market for insurance relating to wildfires and other calamities, leading to higher costs or prohibitively expensive coverage, or limited or unavailability of coverage for certain types of risk. Any of these factors (as well as other factors) could have an adverse effect on the financial condition of any given electric utility, including the City’s Electric System, and likely will affect individual utilities in different ways.
CONSTITUTIONAL LIMITATIONS IN CALIFORNIA
AFFECTING FEES AND CHARGES
Proposition 62
A statutory initiative (“Proposition 62”) was adopted by the voters voting in the State of California at the November 4, 1986 General Election which (1) requires that any tax for general governmental purposes imposed by local governmental entities be approved by resolution or ordinance adopted by two-thirds vote of the governmental agency’s legislative body and by a majority of the electorate of the governmental entity, (2) requires that any special tax (defined as taxes levied for other than general governmental purposes) imposed by a local governmental entity be approved by a two-thirds vote of the voters within that jurisdiction, (3) restricts the use of revenues from a special tax to the purposes or for the service for which the special tax was imposed, (4) prohibits the imposition of ad valorem taxes on real property by local governmental entities except as permitted by Article XIIIA, (5) prohibits the imposition of transaction taxes and sales taxes on the sale of real property by local governmental entities and (6) requires that any tax imposed by a local governmental entity on or after March 1, 1985 be ratified by a majority vote of the electorate within two years of the adoption of the initiative or be terminated by November 15, 1988.
Proposition 218
Proposition 218, a State ballot initiative known as the “Right to Vote on Taxes Act,” was approved by the voters of the State of California on November 5, 1996. Proposition 218 added Articles XIIIC and XIIID to the State Constitution. Article XIIIC imposes a majority voter approval requirement on local governments (including the City) with respect to taxes for general purposes, and a two-thirds voter approval requirement with respect to taxes for special purposes. Article XIIID creates additional requirements for the imposition by most local governments of general taxes, special taxes, assessments and “property-related” fees and charges. Article XIIID explicitly exempts fees for the provision of electric service from the provisions of such article.
Article XIIIC expressly extends the people’s initiative power to the reduction or repeal of local taxes, assessments, and fees and charges imposed prior to its effective date (November 1996). The California Supreme Court held in Bighorn-Desert View Water Agency v. Verjil, 39 Cal.4th 205 (2006) that, under Article XIIIC, local voters by initiative may reduce a public agency’s water rates and delivery charges, as those are property-related fees or charges within the meaning of Article XIIID, and noted that the initiative power described in Article XIIIC may extend to a broader category of fees and charges than the property-related fees and charges governed by Article XIIID. Moreover, in the case of Bock v. City Council of Lompoc, 109 Cal.App.3d 52 (1980), the Court of Appeal determined that an electric rate ordinance was not subject to the same constitutional restrictions that are applied to the use of the initiative process for tax measures so as to render it an improper subject of the initiative process. Thus, electric service charges (which are expressly exempted from the provisions of Article XIIID) may be subject to the initiative provisions of Article XIIIC, thereby subjecting such fees and charges to reduction by the electorate. The City believes that even if the electric rates of the City are subject to the initiative power, Packet Pg. 438 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 66 4909-8297-8690v6/200986-0003
the electorate of the City would be precluded from reducing electric rates and charges in a manner adversely affecting the payment of the 2026 Bonds by virtue of the “impairment of contracts clause” of the United States and California Constitutions.
Proposition 26
The California electorate adopted Proposition 26 at the November 2, 2010 election, amending Article XIIIC of the California Constitution. Proposition 26 was designed to supplement tax limitations California voters adopted when they approved Proposition 13 in 1978 and Proposition 218 in 1996.
Proposition 26 applies by its terms to any levy, charge or exaction imposed, increased or extended by a local government on or after November 3, 2010. Proposition 26 deems any such levy, charge or fee to be a “tax,” requiring voter approval unless it comes within one of the listed exceptions or further exceptions recognized by the courts. Proposition 26 expressly excludes from its definition of a “tax,” among other things, a charge imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product.
Proposition 26 is subject to interpretation by California courts. A number of lawsuits have been filed against public agencies in California relating to electric utility fund transfers. In 2011, two lawsuits were filed against the City challenging the implementation of the City’s “payment in lieu of taxes” (or “PILOT”) transfer from the Electric System to the City’s general fund without voter approval. The City’s PILOT is designed to be equivalent to the ad valorem taxes the Electric System would have had to pay if such electric utility were privately owned. The suits alleged that the PILOT was passed through to the City’s Electric System customers as part of the rates and charges for electric service in excess of the reasonable costs to the City of providing electric service. The Superior Court of the State of California, Shasta County, consolidated the two lawsuits and ruled in favor of the City on July 13, 2012. Following an appeal by the plaintiffs, on February 19, 2015, the Court of Appeal of the State of California, Third Appellate Division, ruled in Citizens for Fair REU Rates v. City of Redding, holding that the City’s PILOT constituted an unconstitutional “tax” under Proposition 26 for which the City was required to secure voter approval unless the City proved that the amount collected was necessary to cover the reasonable costs to the City of providing electric service. In addition, the Court of Appeal noted that Proposition 26 had no retrospective effect as to local taxes that existed prior to November 3, 2010, but found that since the PILOT was subject to the City Council’s recurring discretion, the PILOT did not escape the purview of Proposition 26. On March 2, 2015, the City filed a Petition for Review with the California Supreme Court which was granted. On August 27, 2018, the California Supreme Court rendered its decision reversing the judgment of the Court of Appeal. The California Supreme Court determined that the budgetary transfer from the City electric utility to the City’s general fund, calculated by using the PILOT, itself is not the type of exaction that is subject to Article XIIIC of the California Constitution. The court reasoned that it is only the City’s electric utility rate, not the PILOT, that is imposed on customers for electric service. The California Supreme Court concluded that the challenged rate did not exceed the reasonable costs of providing electric service, and therefore did not constitute a tax.
Due to evolving case law and the uncertainties regarding potential legislative interpretations of Proposition 26, the City is unable to predict at this time how Proposition 26 will ultimately be interpreted by the courts in the context of any particular electric utility rates or what the ultimate impact of Proposition 26 will be.
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Other Initiatives
Articles XIIIC and XIIID and Propositions 62, 218 and 26 were adopted as measures that qualified for the ballot pursuant to California’s initiative process. From time to time, including presently, other initiatives have been, and could be, proposed, and if qualified for the ballot and approved by voters, could affect the City’s Electric System revenues or operations. Neither the nature and impact of these measures nor the likelihood of qualification for ballot or passage can be anticipated by the City.
TAX MATTERS
[In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the City, based upon an analysis of existing laws, regulations, rulings and court decisions, and assuming, among other matters, the accuracy of certain representations and compliance with certain covenants, interest on the 2026 Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 (the “Code”) and is exempt from State of California personal income taxes. Bond Counsel is of the further opinion that interest on the 2026 Bonds is not a specific preference item for purposes of the federal individual alternative minimum tax. Bond Counsel observes that interest on the 2026 Bonds included in adjusted financial statement income of certain corporations is not excluded from the federal corporate alternative minimum tax. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the 2026 Bonds. A complete copy of the proposed form of opinion of Bond Counsel is set forth in Appendix F hereto.
To the extent the issue price of any maturity of the 2026 Bonds is less than the amount to be paid at maturity of such 2026 Bonds (excluding amounts stated to be interest and payable at least annually over the term of such 2026 Bonds), the difference constitutes “original issue discount,” the accrual of which, to the extent properly allocable to each beneficial owner thereof, is treated as interest on the 2026 Bonds which is excluded from gross income for federal income tax purposes and exempt from State of California personal income taxes. For this purpose, the issue price of a particular maturity of the 2026 Bonds is the first price at which a substantial amount of such maturity of the 2026 Bonds is sold to the public (excluding bond houses, brokers, or similar persons or organizations acting in the capacity of underwriters, placement agents or wholesalers). The original issue discount with respect to any maturity of the 2026 Bonds accrues daily over the term to maturity of such 2026 Bonds on the basis of a constant interest rate compounded semiannually (with straightline interpolations between compounding dates). The accruing original issue discount is added to the adjusted basis of such 2026 Bonds to determine taxable gain or loss upon disposition (including sale, redemption, or payment on maturity) of such 2026 Bonds. Beneficial owners of the 2026 Bonds should consult their own tax advisors with respect to the tax consequences of ownership of Bonds with original issue discount, including the treatment of beneficial owners who do not purchase such 2026 Bonds in the original offering to the public at the first price at which a substantial amount of such 2026 Bonds is sold to the public.
2026 Bonds purchased, whether at original issuance or otherwise, for an amount higher than their principal amount payable at maturity (or, in some cases, at their earlier call date) (“Premium 2026 Bonds”) will be treated as having amortizable bond premium. No deduction is allowable for the amortizable bond premium in the case of bonds, like the Premium 2026 Bonds, the interest on which is excluded from gross income for federal income tax purposes. However, the amount of tax-exempt interest received, and a beneficial owner’s basis in a Premium 2026 Bond, will be reduced by the Packet Pg. 440 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 68 4909-8297-8690v6/200986-0003
amount of amortizable bond premium properly allocable to such beneficial owner. Beneficial owners of Premium 2026 Bonds should consult their own tax advisors with respect to the proper treatment of amortizable bond premium in their particular circumstances.
The Code imposes various restrictions, conditions and requirements relating to the exclusion from gross income for federal income tax purposes of interest on obligations such as the 2026 Bonds.
The City has made certain representations and covenanted to comply with certain restrictions, conditions and requirements designed to ensure that interest on the 2026 Bonds will not be included in federal gross income. Inaccuracy of these representations or failure to comply with these covenants may result in interest on the 2026 Bonds being included in gross income for federal income tax purposes, possibly from the date of original issuance of the 2026 Bonds. The opinion of Bond Counsel assumes the accuracy of these representations and compliance with these covenants.
Bond Counsel has not undertaken to determine (or to inform any person) whether any actions taken (or not taken), or events occurring (or not occurring), or any other matters coming to Bond Counsel’s attention after the date of issuance of the 2026 Bonds may adversely affect the value of, or the tax status of interest on, the 2026 Bonds. Accordingly, the opinion of Bond Counsel is not intended to, and may not, be relied upon in connection with any such actions, events or matters.
Although Bond Counsel is of the opinion that interest on the 2026 Bonds is excluded from gross income for federal income tax purposes and is exempt from State of California personal income taxes, the ownership or disposition of, or the accrual or receipt of amounts treated as interest on, the 2026 Bonds may otherwise affect a beneficial owner’s federal, state or local tax liability. The nature and extent of these other tax consequences depends upon the particular tax status of the beneficial owner or the beneficial owner’s other items of income or deduction. Bond Counsel expresses no opinion regarding any such other tax consequences.
Current and future legislative proposals, if enacted into law, clarification of the Code or court decisions may cause interest on the 2026 Bonds to be subject, directly or indirectly, in whole or in part, to federal income taxation or to be subject to or exempted from state income taxation, or otherwise prevent beneficial owners from realizing the full current benefit of the tax status of such interest. The introduction or enactment of any such legislative proposals, clarification of the Code or court decisions may also affect, perhaps significantly, the market price for, or marketability of, the 2026 Bonds. Prospective purchasers of the 2026 Bonds should consult their own tax advisors regarding the potential impact of any pending or proposed federal or state tax legislation, regulations or litigation, as to which Bond Counsel expresses no opinion.
The opinion of Bond Counsel is based on current legal authority, covers certain matters not directly addressed by such authorities, and represents Bond Counsel’s judgment as to the proper treatment of the 2026 Bonds for federal income tax purposes. It is not binding on the Internal Revenue Service (“IRS”) or the courts. Furthermore, Bond Counsel cannot give and has not given any opinion or assurance about the future activities of the City, or about the effect of future changes in the Code, the applicable regulations, the interpretation thereof or the enforcement thereof by the IRS. The City has covenanted, however, to comply with the requirements of the Code.
Bond Counsel’s engagement with respect to the 2026 Bonds ends with the issuance of the 2026 Bonds, and, unless separately engaged, Bond Counsel is not obligated to defend the City or the beneficial owners regarding the tax-exempt status of the 2026 Bonds in the event of an audit examination by the IRS. Under current procedures, beneficial owners would have little, if any, right to participate in the audit examination process. Moreover, because achieving judicial review in Packet Pg. 441 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 69 4909-8297-8690v6/200986-0003
connection with an audit examination of 2026 Bonds is difficult, obtaining an independent review of IRS positions with which the City legitimately disagree may not be practicable. Any action of the IRS, including but not limited to selection of the 2026 Bonds for audit, or the course or result of such audit, or an audit of bonds presenting similar tax issues, may affect the market price for, or the marketability of, the 2026 Bonds, and may cause the City or the beneficial owners to incur significant expense.
Payments on the 2026 Bonds generally will be subject to U.S. information reporting and possibly to “backup withholding.” Under Section 3406 of the Code and applicable U.S. Treasury Regulations issued thereunder, a non-corporate beneficial owner of 2026 Bonds may be subject to backup withholding with respect to “reportable payments,” which include interest paid on the 2026 Bonds and the gross proceeds of a sale, exchange, redemption, retirement or other disposition of the 2026 Bonds. The payor will be required to deduct and withhold the prescribed amounts if (i) the payee fails to furnish a U.S. taxpayer identification number (“TIN”) to the payor in the manner required, (ii) the IRS notifies the payor that the TIN furnished by the payee is incorrect, (iii) there has been a “notified payee underreporting” described in Section 3406(c) of the Code or (iv) the payee fails to certify under penalty of perjury that the payee is not subject to withholding under Section 3406(a)(1)(C) of the Code. Amounts withheld under the backup withholding rules may be refunded or credited against a beneficial owner’s federal income tax liability, if any, provided that the required information is timely furnished to the IRS. Certain beneficial owners (including among others, corporations and certain tax-exempt organizations) are not subject to backup withholding. The failure to comply with the backup withholding rules may result in the imposition of penalties by the IRS.]
LITIGATION
There is no action, suit or proceeding known to be pending or threatened, restraining or enjoining the issuance or delivery of the 2026 Bonds, the Indenture or the Continuing Disclosure Agreement, or in any way contesting or affecting the validity of the foregoing or any proceedings of the City taken with respect to any of the foregoing.
To the best knowledge of the City, there is no litigation pending or threatened, questioning the corporate existence of the City, or the title of the officers of the City to their respective offices, or the power and authority of the City to execute and deliver the 2026 Bonds, the Indenture or the Continuing Disclosure Agreement or to perform its obligations under the foregoing. To the best knowledge of the City, there is no litigation pending or threatened, questioning or affecting in any material respect any of the financial information with respect to the City’s Electric System contained in this Official Statement.
At any given time, including the present, there are certain other claims and disputes, including those currently in litigation, that arise in the normal course of the City’s activities. Such matters could, if determined adversely to the City, affect expenditures by the City, and in some cases, its Electric System revenues. See “THE ELECTRIC SYSTEM – Litigation Affecting the Electric System” and “CONSTITUTIONAL LIMITATIONS IN CALIFORNIA AFFECTING FEES AND CHARGES – Proposition 26.” The City’s management and its City Attorney are of the opinion that no pending actions are likely to have a material adverse effect on the City’s ability to perform its obligations under the Indenture and the 2026 Bonds.
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RATING
Fitch Ratings (“Fitch”) has assigned the 2026 Bonds the rating of “[___].” Fitch’s rating outlook with respect to the 2026 Bonds is “[_______].” No application has been made to any other rating agency for the purpose of obtaining any additional rating on the 2026 Bonds. Such rating expresses only the view of the rating agency and an explanation of the significance of such rating may be obtained only from such rating agency as follows: Fitch Ratings, 33 Whitehall Street, New York, New York 10004. Generally, a rating agency bases its credit rating on the information and materials furnished to it (which may include information and material from the City which is not included in this Official Statement) and on investigations, studies and assumptions of its own. A securities rating is not a recommendation to buy, sell or hold securities. There is no assurance that such rating (or any rating outlook ascribed thereto) will continue for any given period of time or that it will not be revised or withdrawn entirely if, in the judgment of such rating agency, circumstances so warrant. Any such downward revision or withdrawal of such rating could have an adverse effect on the market price of the 2026 Bonds.
CONTINUING DISCLOSURE
The City has covenanted for the benefit of the holders and beneficial owners of the 2026 Bonds to provide in an Annual Report certain financial information and operating data relating to the City and the Electric System by not later than 270 days following the end of the City’s Fiscal Year (which Fiscal Year presently ends June 30), commencing with the report for the 2025-26 Fiscal Year, and to provide notices of the occurrence of certain enumerated events. The Annual Report and notices of enumerated events will be provided by or on behalf of the City to the Municipal Securities Rulemaking Board through the Electronic Municipal Market Access (EMMA) system. The specific nature of the information to be contained in the Annual Report and the notice of specified events is summarized in “APPENDIX E – PROPOSED FORM OF CONTINUING DISCLOSURE AGREEMENT.” These covenants have been made in order to assist the Underwriter in complying with the Rule.
In the last five years, certain deficiencies in performance by the City, including the City, as the Successor Agency to the Redding Redevelopment Agency (the “Successor Agency”) under their respective continuing disclosure undertakings have occurred. In that period, annual report information deficiencies are noted for each of the fiscal years identified below, including with respect to various items of the financial and operating data information specified under the continuing disclosure undertakings for the: (i) Redding Joint Powers Financing Authority Water and Wastewater Refunding Revenue Bonds, 2013 Series A and City of Redding Wastewater System Refunding Revenue Bonds, Series 2020 (Fiscal Years 2020-2022); (ii) Redding Joint Powers Financing Authority Lease Refunding Revenue Bonds (2019 Capital Projects), Series 2019A (Fiscal Years 2019-2022); and (iii) Redding Redevelopment Agency Canby-Hilltop-Cypress Project Area Housing Set-Aside Tax Allocation Bonds, 2001 Series B (Fiscal Years 2019 and 2020). In addition, with respect to the Redding Joint Powers Financing Authority Water and Wastewater Refunding Revenue Bonds, 2013 Series A and City of Redding Wastewater System Refunding Revenue Bonds, Series 2020, the City did not timely file its annual report with respect to Fiscal Year 2019-20, and did not file notice of such failure to timely file, but made a filing of such annual report on January 6, 2022, approximately 10 months late. With respect to the Transmission Agency of Northern California California-Oregon Transmission Project Revenue Refunding Bonds, 2016 Series A, the City’s audited financial statements and financial and operating data information were not properly linked to two of the CUSIPs for those bonds for Fiscal Year 2023. Also in the last five-years, on October 7, Packet Pg. 443 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 71 4909-8297-8690v6/200986-0003
2021 and June 29, 2023, ratings upgrades were made on the Successor Agency’s outstanding tax allocation bonds, for which the Successor Agency failed to make event notices. The City and the Successor Agency, respectively, have made the necessary filings, posted to EMMA, to address the deficiencies, including notices of the failures to timely make such filings, for all currently outstanding bonds identified above.
UNDERWRITING
The 2026 Bonds are being purchased for reoffering by J.P. Morgan Securities LLC (the “Underwriter”) pursuant to a bond purchase contract (the “Purchase Contract”), by and between the Underwriter and the City. The Underwriter has agreed, subject to certain conditions, to purchase the 2026 Bonds at a price of $___________ (representing the $__________ aggregate principal amount of the 2026 Bonds [plus/less] $_________ [net] original issue [premium/discount] and less $__________ of Underwriter’s discount). The Purchase Contract for the 2026 Bonds provides that the Underwriter is obligated to 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 the Purchase Contract.
The Underwriter may offer and sell the Bonds to certain dealers and others at prices lower than the initial public offering prices stated on the inside cover page hereof. The offering prices may be changed from time to time by the Underwriter.
The following information has been provided by the Underwriter for inclusion in this Official Statement: J.P. Morgan Securities LLC (“JPMS”), the Underwriter of the 2026 Bonds, has entered into negotiated dealer agreements (each, a “Dealer Agreement”) with each of Charles Schwab & Co., Inc. (“CS&Co.”) and LPL Financial LLC (“LPL”) for the retail distribution of certain securities offerings at the original issue prices. Pursuant to each Dealer Agreement, each of CS&Co. and LPL may purchase 2026 Bonds from JPMS at the original issue price less a negotiated portion of the selling concession applicable to any 2026 Bonds that such firm sells.
CERTAIN RELATIONSHIPS
The Underwriter and its affiliates are full service financial institutions engaged in various activities, which may include securities trading, commercial and investment banking, financial advisory, investment management, principal investment, hedging, financing and brokerage activities.
The Underwriter and its affiliates have, from time to time, performed, and may in the future perform, various investment banking services for the City, for which they received or will receive customary fees and expenses.
In the ordinary course of their various business activities, the Underwriter and its affiliates may make or hold a broad array of investments and actively trade debt and equity securities (or related derivative securities) and financial instruments (which may include bank loans and/or credit default swaps) for their own account and for the accounts of their customers and may at any time hold long and short positions in such securities and instruments. Such investment and securities activities may involve securities and instruments of the City.
CERTAIN LEGAL MATTERS
The validity of the 2026 Bonds and certain other legal matters are subject to the approving opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the City. A complete copy of the Packet Pg. 444 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) 72 4909-8297-8690v6/200986-0003
proposed form of Bond Counsel opinion is contained in Appendix F hereto. Bond Counsel undertakes no responsibility for the accuracy, completeness or fairness of this Official Statement and expresses no opinion with respect thereto. Stradling Yocca Carlson & Rauth LLP is serving as Disclosure Counsel to the City in connection with the 2026 Bonds. Certain legal matters will also be passed upon for the City by the City Attorney of the City of Redding, and for the Underwriter by Norton Rose Fulbright US LLP. Bond Counsel and Disclosure Counsel will receive compensation that is contingent upon the issuance and delivery of the 2026 Bonds.
MUNICIPAL ADVISOR
The City has retained PFM Financial Advisors LLC, Los Angeles, California, as municipal advisor (the “Municipal Advisor”) in connection with the issuance of the 2026 Bonds. The Municipal Advisor 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 financial advisory firm and is not engaged in the business of underwriting, trading or distributing municipal securities or other public securities. The payment of certain fees of the Municipal Advisor is contingent upon the issuance and delivery of the 2026 Bonds.
AUDITED FINANCIAL STATEMENTS
The City’s Annual Comprehensive Financial Report for the Fiscal Year ended June 30, 2025, including its Basic Financial Statements, are included in Appendix A to this Official Statement. The City’s Basic Financial Statements as of and for year ended June 30, 2025 have been audited by CliftonLarsonAllen LLP, independent accountants (the “Independent Accountants”) as stated in their report appearing in Appendix A. The 2026 Bonds are special obligations of the City payable solely from the Net Revenues of the City’s Electric System and moneys in the City’s Electric Revenue Fund.
The financial statements of the City are public documents and the City has not requested nor did the City obtain permission from the Independent Accountants to include the Basic Financial Statements and their report in an Appendix to this Official Statement. Accordingly, the Independent Accountants have made no representation in connection with inclusion of the audit herein that there has been no material change in the financial condition of the City or the Electric System since the most recent audit was concluded. The Independent Accountants have not been engaged to perform and have not performed, since the date of its report included in Appendix A, any procedures on the financial statements addressed in that report. The Independent Accountants also have not performed any procedures relating to this Official Statement.
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EXECUTION AND DELIVERY
The execution and delivery of this Official Statement has been duly authorized by the City.
CITY OF REDDING
By
City Manager
By
Director of Electric Utility
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APPENDIX A
EXCERPTS OF THE AUDITED FINANCIAL STATEMENTS OF THE CITY FOR THE FISCAL YEAR ENDED JUNE 30, 2025
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APPENDIX B
CERTAIN INFORMATION CONCERNING THE CITY OF REDDING
The economic and demographic information regarding the City provided in this Appendix B is presented as general background data and has been collected from sources which the City deems to be reliable. The general fund of the City is not liable, and the credit or taxing power of the City is not pledged, for the payment of the 2026 Bonds or the interest thereon. The 2026 Bonds are not secured by a legal or equitable pledge of, or charge, lien or encumbrance upon, any of the property of the City, or any of its income or receipts, except the Net Revenues of the City’s Electric System and the other funds which are pledged to the payment of the 2026 Bonds pursuant to the Indenture. See the section in the Official Statement entitled “SECURITY AND SOURCES OF PAYMENT FOR THE 2026 BONDS.” General Description
The City of Redding (the “City” or “Redding”), comprising approximately 62 square miles, is located at the northern end of the Sacramento Valley, approximately 160 miles north of Sacramento and 230 miles northeast of San Francisco. It is the county seat of Shasta County and the major trade, recreational and commerce center for the northern central and northeastern portion of California.
The City is situated in the midst of a vast recreational area that includes nine national forests, six wilderness areas, two state parks and one national park. The City experiences hot summers and mild winters. Annual precipitation is approximately 34.23 inches. Elevation within the area varies from 400 feet above sea level to 10,466 feet at Lassen Park, just outside the County of Shasta (the “County”).
Municipal Government
The City was incorporated on October 4, 1887 and operates as a general law city with the council-manager form of government. The City Council consists of five members elected “at large” for four-year staggered terms. Council members must be residents of the City and registered voters both at the time nomination papers are taken out and assuming office. The Mayor is selected by the City Council from among its members.
City Council Members. The current members of the City Council are as follows:
MIKE LITTAU, Mayor, was elected to the City Council in November 2024. Mr. Littau moved to Redding in 1995 and attended Simpson University. Mr. Littau’s education includes a bachelor’s degree in Communications. After graduating from college, Mr. Littau served in the Army. Following his military service, he began his career working for a local bank and insurance company in Redding. In 2005, he opened his own insurance business. Mr. Littau’s community involvement includes serving on a local school board, as well as serving in various leadership roles for the California Soccer Park, Redding Youth Soccer League, and Simpson Alumni Association. Mr. Littau’s current term of office ends in December 2028.
DR. PAUL DHANUKA, Vice Mayor, was elected to the City Council in November 2024. Dr.
Dhanuka has served as a medical doctor in the Redding community and North State region for nearly two decades. He is a former Chief of Medical Staff at Mercy Medical Center Redding and at Shasta Regional Medical Center Redding. Dr. Dhanuka is the current President of the North Valley Medical Association, and an Assistant Professor at the University of California, Davis School of Medicine and California University of Science and Medicine. He serves on the Shasta County Public Health Advisory Board, Packet Pg. 448 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) B-2
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Simpson University’s Community Advisory Committees, and Turtle Bay Exploration Park Board of Regents. Dr. Dhanuka’s current term of office ends in December 2028.
ERIN RESNER, Council member and Mayor Pro Tempore, was elected to the City Council in November 2024. Ms. Resner was raised in Redding. Her education includes a bachelor’s degree in Biology, with a minor in Environmental Sciences, from St. Mary’s College of California. Ms. Resner and her husband currently own eight locations of Dutch Bros. Coffee in Redding, Anderson, and Palo Cedro, California. Ms. Resner’s community involvement includes serving as a Court Appointed Special Advocate for youth in Dependency Court for over a decade and as a Commissioner for the City of Redding’s Community Services Advisory Commission for four years. She is involved in a number of community focused non-profits and businesses such as One Safe Place and Turtle Bay and is also on the Children’s Legacy Center Board of Directors serving as the Treasurer. Ms. Resner’s current term of office ends in December 2026.
TENESSA AUDETTE, Council member, was elected to the City Council in November 2022. Ms.
Audette’s education includes a bachelor’s degree in Political Science from Sonoma State University. She started a small business, Called to Action Consulting, Inc., which managed campaigns for city council, county supervisor, district attorney, congressional, assembly and gubernatorial races. Ms. Audette serves as the First District’s Representative for the California State Senate. She is a graduate of Leadership Redding, a program of the Community Foundation of the North State, the stated purpose of which is to serve as a catalyst for individuals who seek participation in community decision-making in voluntary and governmental organizations. She served on the Leadership Redding Steering Committee, organizing the government program for five years. She also served as the Data Chair on the Shasta County Republican Central Committee and was a delegate for the California GOP. Ms. Audette is an Adjunct Instructor teaching constitutional principles and civics as an elective for Bethel School of Supernatural Ministry.
Ms. Audette’s current term of office ends in December 2026.
JACK MUNNS, Mayor, was elected to the City Council in November 2022. Mr. Munns was born and raised in Redding. In 1989, he joined the Reno Police Department where he served for [__] years.
Mr. Munns returned to the City in [___]. Mr. Munns’ education includes a bachelor’s degree in Criminal Justice and a master’s degree in Social Work, which he obtained while working as a police officer. Mr.
Munns’ current term of office ends in December 2026.
City Management and Employees. The City Manager is appointed by the City Council and is responsible for implementation of Council policies and for day-to-day operation of the City. The offices of City Clerk and City Treasurer are elective, for four-year terms, and the City Attorney is appointed by the City Council. The City is regarded as a full service city and municipally provided services include planning and building regulation, police protection, fire protection, recreation and parks, electric, water, wastewater, storm drainage and solid waste collection and disposal and operation of two airports.
As of June 30, 2025, a staff of [___] full-time employees and [___] part-time employees of the City carried out the functions of municipal government. City employees have been represented by various unions since 1965.
Population Characteristics
Between 1980 and 2020, the City grew significantly, increasing to 93,746 residents in 2020 from 41,995 residents in 1980. The City’s estimated 2025 population of 93,534 represents a slight decrease of approximately 0.23% from the 2020 U.S. Census tabulation. The City’s population represents over 50% of the County’s estimated population of 180,201 in 2025. The following table indicates population growth for the City and the County from 1980 to 2025.
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CITY OF REDDING AND COUNTY OF SHASTA
POPULATION
(1980, 1990, 2000, 2010 and 2020 as of April 1;
2021-2025 as of January 1, with 2020 benchmark)
City of Redding County of Shasta
Year Number
Annualized
Percent Change
Over Interval Number
Annualized
Percent Change
Over Interval
1980 41,995 – 115,715 –
1990 66,462 5.83% 147,036 2.71%
2000 80,865 2.17 163,256 1.10
2010 89,861 1.11 177,223 0.86
2020 93,746 0.43 182,155 0.28
2021 93,536 (0.22) 181,483 (0.36)
2022 92,682 (0.91) 180,206 (0.70)
2023 92,164 (0.55) 179,122 (0.60)
2024 92,466 0.32 179,195 0.04
2025 93,534 1.16 180,201 0.56
__________________
Source: State of California, Department of Finance, E-4 Population Estimates for Cities, Counties, and the State, 1980-2020 Census data, 2021-2025 with 2020 Census Benchmark. Sacramento, California, May 2025.
Industry and Employment
Timber extraction and the processing of wood by-products, together with agriculture, tourism and government, have historically been the major sectors of employment in Redding. Over the last decade, the City’s economic base has diversified from resource extraction and processing activities, primarily lumber, to a regional services economy supported by retail and wholesale trade plus educational, recreational, medical and government services for an area covering several counties. The City has attracted new manufacturing industries through a combination of industrial development policies, the availability of a growing labor pool, comparatively low development and living costs and inexpensive power. A consistent factor in the growth of the labor force continues to be the out-migration of all types of workers from the population centers of Southern California and the San Francisco Bay Area to Shasta County and other Northern California counties. A large portion of the in-migrants possesses high technical and administrative skills.
Major employers in the City and Shasta County include those in medical services, government and utility services. Major non-governmental employers, their products or services, and the number of their respective employers in 2025 are listed in the following table:
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CITY OF REDDING
MAJOR EMPLOYERS
(as of June 30, 2025)
Employer Employees Rank
Percentage
of Total Area
Employment
Mercy Medical Center 2,239 1 2.92%
Shasta County(1) 1,779 2 2.32
City of Redding(2) 961 3 1.25
Shasta Regional Medical Center 679 4 0.89
California Transportation Department 599 5 0.78
Shasta Union High School District 582 6 0.76
Shasta Community College 521 7 0.68
Shasta Community Health 500 8 0.65
Win-River Casino 366 9 0.48
Redding Rancheria 351 10 0.46
Total 8,577 11.18%
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(1) Full-time equivalent budgeted positions. This includes employees who work outside of the City. (2) Full-time budgeted positions. In Fiscal Year 2024-25, there were [___] full-time and [___] part-time/temporary positions filled.
Source: City of Redding Annual Comprehensive Financial Report for Fiscal Year 2024-25. Derived roughly from the State of California Employment Development Department’s listing of the top 25 employers in Shasta County.
The Redding Metropolitan Statistical Area (MSA) is comprised of Shasta County. The following table summarizes employment by industry in Shasta County in calendar years 2020 through 2024 (most recent full year information available). The calendar year figures presented are annual averages which are estimated by the State of California Employment Development Department.
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LABOR FORCE IN SHASTA COUNTY
AVERAGE ANNUAL EMPLOYMENT BY INDUSTRY
2020 through 2024
2020 2021 2022 2023 2024
Wage and Salary Employment:
Farm ........................................... 800 900 1,000 1,000 1,000 Mining, Logging, and
Construction ............................. 4,400 4,400 4,400 4,400 4,500 Manufacturing............................ 2,500 2,800 2,900 2,900 3,000 Trade, Transportation and
Utilities..................................... 13,000 13,400 13,600 13,200 13,000 Information Services.................. 500 500 500 500 500 Financial Activities.................... 2,800 2,800 2,900 3,000 3,100 Professional and Business
Services ................................... 5,800 5,800 6,100 6,200 6,200 Private Education and
Health Services ........................ 15,200 15,100 15,600 16,400 16,700 Leisure and Hospitality .............. 6,200 6,900 7,200 7,200 6,900 Other Services............................ 2,300 2,300 2,400 2,600 2,700 Government................................ 13,200 13,100 13,400 14,000 14,700 Total(1)................................... 66,600 68,000 69,700 71,100 72,200 __________________
(1) Columns may not add to totals due to independent rounding.
Source: California Employment Development Department. Annual Averages; March 2024 Benchmark.
According to the California Employment Development Department, the City’s metropolitan area (i.e., Shasta County) annual average unemployment rate was 5.3% in 2024. The following table sets forth certain information regarding employment in the Redding Metropolitan Statistical Area from 2020 through 2024.
REDDING METROPOLITAN STATISTICAL AREA
CIVILIAN LABOR FORCE, EMPLOYMENT AND UNEMPLOYMENT
2020 through 2024
Year Labor Force
Unemployment
Number Rate
2020 73,300 6,500 8.9%
2021 72,800 5,000 6.9
2022 72,500 3,400 4.7
2023 73,900 3,800 5.1
2024 79,300 4,200 5.3
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Source: California Employment Development Department; Revised annual averages (not seasonally adjusted) March 2024 Benchmark.
Construction Activity
The following table sets forth the valuation and number of units for new single- and multi-family dwellings and businesses located in the City for the five calendar years 2021 through 2025.
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CITY OF REDDING
BUILDING VALUATIONS AND NUMBER OF UNITS
2021 through 2025
(Dollars in Thousands)
2021 2022 2023 2024 2025(4)
Single Family Units......................... 151 234 94 112 163 Value Single Family(1)..................... $42,510.7 $76,110.7 $36,660.3 $45,722.6 $61,464.2 Multi-Family Units.......................... 244 52 0 61 0 Multi-Family Permits(2)................... 3 4 0 3 0
Value Multi-Family Dwellings........ $38,036.4 $9,031.6 $0 $9,295.8 $0 Business Permits ............................. 33 23 23 17 15 Value Business ................................ $46,433.7 $44,679.7 $36,936.1 $34,006.4 $43,458.1 Total Permits(3)................................ 5,310 4,675 3,883 3,616 3,671 Value Total All Permits(3)................ $164,855.5 $192,655.3 $116,809.5 $144,828.9 $171,678.2 __________________
(1) Value of new construction only.
(2) Includes hotel and apartment units – “R” occupancies. (3) Total includes miscellaneous structures and additions, alterations and remodels in addition to new construction. (4) Figures as of November 30, 2025.
Source: City of Redding Development Services Department.
Commerce
The City is a regional center of commerce for several Northern California counties, with many shopping centers and malls. Support for retail sales is derived from a retail trade area population of approximately 128,000 in the primary trade area and approximately 257,000 people in the secondary trade area. The primary trade area consists of the metropolitan urban area, including the cities of Redding, Shasta Lake, Anderson and Red Bluff. The secondary trade area consists of Shasta, Trinity, and Tehama counties.
The following table shows the annual volume of taxable sales within the City since 2020. Taxable transactions in the City were reported to be approximately $2.51 billion in calendar year 2024.
CITY OF REDDING
TAXABLE TRANSACTIONS
Calendar Years 2020 through 2024
(Dollars In Thousands)
Year
Retail and Food Services
Taxable Transactions
Total All Outlets Taxable
Transactions
2020 $1,766,878 $2,276,483
2021 2,044,445 2,608,210
2022 2,001,843 2,607,234
2023 1,940,192 2,560,254
2024 1,901,277 2,516,487
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Source: California Department of Tax and Fee Administration - Taxable Sales in California Packet Pg. 453 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) B-7
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Personal Income
The United Department of Commerce, Bureau of Economic Analysis (the “BEA”) produces economic accounts statistics that enable government and business decision-makers, researchers, and the public to follow and understand the performance of the national economy.
The BEA defines “personal income” as income received by persons from all sources, including income received from participation in production as well as from government and business transfer payments. Personal income represents the sum of compensation of employees (received), supplements to wages and salaries, proprietors’ income with inventory valuation adjustment and capital consumption adjustment (“CCAdj”), rental income of persons with CCAdj, personal income receipts on assets, and personal current transfer receipts, less contributions for government social insurance. Per capita personal income is calculated as the personal income divided by the resident population based upon the Census Bureau’s annual midyear population estimates.
The following table presents total personal income and per capita personal income for the Redding Metropolitan Statistical Area (which is the same as the County of Shasta), the State and the United States for the period 2019 through 2023.
REDDING METROPOLITAN STATISTICAL AREA,
STATE OF CALIFORNIA AND UNITED STATES
PERSONAL INCOME AND PER CAPITA PERSONAL INCOME
Calendar Years 2019 through 2023(1)
Year Area
Personal Income
(millions of dollars)
Per Capita Personal
Income (dollars)
2019 Redding MSA $ 8,321.8 $45,675
California 2,539,747.4 64,219
United States 18,349,584.0 55,566
2020 Redding MSA $ 9,325.8 $51,240
California 2,769,103.0 70,098
United States 19,600,945.0 59,123
2021 Redding MSA $ 9,905.5 $54,385
California 3,009,556.6 76,882
United States 21,403,979.0 64,460
2022 Redding MSA $ 9,788.5 $54,099
California 3,003,826.1 76,941
United States 22,077,232.0 66,244
2023 Redding MSA $ 10,395.7 $57,637
California 3,166,135.4 81,255
United States 23,380,269.0 69,810
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(1) Latest available annual data. SAINC1 National and State data updated September 2024 – revised statistics for 2019-2023; CAINC1 MSA data updated November 2024 – new statistics for 2023; revised statistics for 2019- 2022; data not adjusted for inflation.
Source: Bureau of Economic Analysis: SAINC1 National and State data; CAINC1 MSA data.
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Transportation
The City enjoys a strategic market location among the Pacific Coast States of California, Oregon and Washington. Interstate 5, the principal transportation artery running north-south from Mexico to Canada, connects the City to the entire Pacific Coast marketplace. The City lies an equal distance (approximately 600 miles) between Los Angeles, California and Seattle, Washington. The City is also bisected by State Highway 299 and State Route 44, the key east-west transportation arteries in northern California. Interstate 5 also provides industrial and manufacturing firms in the County with freightdelivery schedules to the Midwest and the East Coast.
The City is served by Amtrak for rail transportation and Greyhound for bus service. Eight truck terminals are located in the County and daily service is provided by six major carriers.
The Redding Area Bus Authority (“RABA”) is the City’s multi-bus transportation system and offers 15 different fixed routes and a commuter service to provide transportation to the rural city of Burney. RABA also operates the Americans with Disability Act (ADA) Paratransit service providing service for individuals who, because of a disability, are not able to utilize the fixed route system. The service area of the RABA system covers well over 100 square miles.
The Redding Regional Airport serves the regional area of Northern California, consisting of approximately 25,000 square miles covering eight counties. Commercial, freight and passenger services are provided by United Express/SkyWest Airlines, Alaska Airlines, Avelo Airlines, Federal Express, UPS and charter service providers. The Redding Municipal Airport features a 32,000 square foot terminal building to serve the traveling public that was expanded and remodeled in 2014.
Utilities
Electricity, solid waste collection and disposal, water, storm drainage, and wastewater services are provided by enterprise operations owned and operated by the City. Natural gas is provided by Pacific Gas and Electric Company (PG&E).
Community Services
Students in the Redding area attend school at one of 45 elementary schools and middle/junior high schools, 15 charter schools, 1 regional occupation programs and 18 high schools. There are several higher education institutions in the immediate area offering bachelor's and master’s degrees: Chico State University Center for Regional and Continuing Education (located in the Health Science & University Center in downtown Redding), National University, Simpson University, and Shasta Bible College & Graduate School. Shasta Community College, a two-year institution, offers both day and evening courses to approximately 10,000 students. In addition, several Vocational & Technical schools offer a diverse range of programs.
The City’s parks system includes 59 developed parks and facilities, encompassing over 482 developed acres. The park system includes nearly 180 acres of natural area parks, 40-plus miles of Cityowned trails, and 17 special purpose facilities and almost 1,000 acres of natural open space. The special purposes facilities include the Redding Civic Auditorium; the Redding Sports Park; the California Soccer Park; the Redding Aquatics Center; the Senior Citizens Center; the Martin Luther King Jr. Community Center; the Benton Dog Park; and three boat ramp facilities accessing the Sacramento River.
The City serves as the primary medical center for Northern California. The City’s two general care hospitals serve approximately 330,000 people in Shasta, Tehama, Trinity, Siskiyou, and Lassen Packet Pg. 455 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) B-9
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counties. The two largest hospitals have a total of 492 beds and employ approximately 2,918 full-time staff employees. In addition, the City has several specialized health care facilities.
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APPENDIX C
BOOK-ENTRY ONLY SYSTEM
General
The Depository Trust Company (“DTC”), New York, New York will act as securities depository for the 2026 Bonds. The 2026 Bonds will be issued as fully-registered securities certificates 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 will be delivered for each maturity of the 2026 Bonds, in the aggregate principal amount of such maturity, 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. 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 for 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 DTC’s participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com. The information on such website is not incorporated herein by reference.
Purchases of the 2026 Bonds under the DTC book-entry 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 ownership interests in the 2026 Bonds, except in the event that use of the book-entry system for the 2026 Bonds is discontinued.
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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 representatives 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 the 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 Indenture. 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 bond registrar and request that copies of notices be provided directly to them.
Redemption notices shall be sent to DTC. If less than all of a maturity of the 2026 Bonds within an issue are being redeemed, DTC’s practice is to determine by lot the amount of the interest of each Direct Participant in such maturity to be redeemed.
Neither DTC nor Cede & Co. (nor such other DTC nominee) will consent or vote with respect to the 2026 Bonds unless authorized by a Direct Participant in accordance with DTC’s MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the City 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 the 2026 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy).
Principal, premium, if any, and interest payments with respect to 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 City or the Trustee, on each payment date in accordance with their respective holdings shown on DTC’s records. Payments by Participants to Beneficial Owner will be governed by standing instructions and customer 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 Participant and not of DTC, the Trustee or the City, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of principal and interest to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC, is the responsibility of the City 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 shall be 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 City or the Trustee. Under such circumstances, in the event that a successor depository is not obtained, 2026 Bonds are required to be printed and delivered.
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The City may decide to discontinue use of the system of book-entry transfers through DTC (or a successor securities depository). In that event, certificates will be printed and delivered.
The foregoing description concerning DTC and DTC’s book-entry system is based solely on information furnished by DTC. No representation is made herein by the City or the Underwriter as to the accuracy or completeness of such information, and the City and the Underwriter take no responsibility for the accuracy or completeness thereof.
Discontinuance of DTC Services
In the event that (a) DTC determines not to continue to act as securities depository for the 2026 Bonds or (b) the City determines to remove DTC from its functions as a depository, DTC’s role as securities depository for the 2026 Bonds and use of the book-entry system will be discontinued. If the City fails to select a qualified securities depository to replace DTC, the City will cause the Trustee to execute and deliver new 2026 Bonds in fully registered form in such denominations and numbered in the manner determined by the Trustee and registered in the names of such persons as are requested in a written request of the City. The Trustee shall not be required to deliver such new 2026 Bonds within a period of less than 60 days from the date of receipt of such written request of the City. Upon such registration, such persons in whose names the 2026 Bonds are registered will become the registered owners of the 2026 Bonds for all purposes.
In the event that the book-entry system is discontinued, the following provisions would also apply: (a) any 2026 Bonds may, in accordance with their terms, be transferred on the books maintained by the Trustee under the Indenture for such purpose by the person in whose name it is registered, in person or by the duly authorized attorney of such person, upon payment by the Owner requesting such transfer of any tax or other governmental charge required to be paid with respect to such transfer as a condition precedent to the exercise of such privilege, and upon the surrender of such 2026 Bond for cancellation accompanied by a duly executed written instrument of transfer in a form approved by the Trustee; (b) 2026 Bonds may be exchanged at the principal corporate trust office of the Trustee for a like aggregate principal amount of 2026 Bonds of the same maturity of other authorized denominations, upon payment by the Owner requesting such exchange of any tax or other governmental charge required to be paid with respect to such transfer as a condition precedent to the exercise of such privilege; (c) the Trustee shall not be required to register the transfer of or exchange any 2026 Bonds during the fifteen days preceding each interest payment date, or to register the transfer of or exchange any 2026 Bond which has been selected for redemption in whole or in part, from after the day of mailing of a notice of redemption of such 2026 Bond; (d) all interest payments on the 2026 Bonds will be made on the interest payment dates therefor as provided in the Indenture to the person whose name appears on the registration books maintained by the Trustee as the Owner thereof at the close of business on the last day of the month immediately preceding an interest payment date (the “Record Date”), whether or not such day is a Business Day, such interest to be paid by check mailed by first-class mail to such registered Owner at the address as it appears in such registration books on the Record Date, except in the case of an Owner of at least $1,000,000 in aggregate principal amount of 2026 Bonds the Outstanding, payment shall be made at such Owner’s option by wire transfer of immediately available funds to an account in a bank or trust company or savings bank that is a member of the Federal Reserve System and that is located in the United States of America according to written instructions given by such Owner to the Trustee by the applicable record date; and (e) all payments of principal of and premium, if any, on the 2026 Bonds will be payable in lawful money of the United States of America by check upon surrender of the 2026 Bonds at the principal corporate trust office of the Trustee at maturity or upon its prior redemption.
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APPENDIX D
SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE
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APPENDIX E
PROPOSED FORM OF CONTINUING DISCLOSURE AGREEMENT
This Continuing Disclosure Agreement (the “Disclosure Agreement”), dated [Closing Date], 2026, is executed and delivered by the City of Redding, California (the “City”) and U.S. Bank Trust Company, National Association in its capacity as dissemination agent (the “Dissemination Agent”) in connection with the issuance of $[Par] aggregate principal amount of City of Redding Electric System Refunding Revenue Bonds, Series 2026 (the “Bonds”). The Bonds are being issued pursuant to an Indenture, dated as of July 1, 2026 (the “Indenture”), by and between the City and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). In connection therewith the City and the Trustee covenant and agree as follows:
Purpose of this Disclosure Agreement. This Disclosure Agreement is being executed and delivered by the City and the Dissemination Agent for the benefit of the Holders and Beneficial Owners of the Bonds and in order to assist the Participating Underwriter (as defined herein) in complying with Securities and Exchange Commission Rule 15c2-12(b)(5).
Definitions. In addition to the definitions set forth above and in the Indenture, which apply to any capitalized term used in this Disclosure Agreement unless otherwise defined in this Section 2, the following capitalized terms shall have the following meanings:
“Annual Report” shall mean any Annual Report provided by the City pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. “Beneficial Owner” shall mean any person who (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 City Manager or the Director of Finance of the City, or such other officer or employee as the City shall designate in writing to the Trustee from time to time.
“Dissemination Agent” shall mean initially, U.S. Bank Trust Company, National Association, acting in its capacity as Dissemination Agent hereunder, or any successor Dissemination Agent designated in writing by the City and which has filed with the Trustee a written acceptance of such designation.
“Holder” shall mean either the registered owners of the Bonds or, if the Bonds are registered in the name of The Depository Trust Company or another recognized depository, any applicable participant in such depository system.
“Listed Event” shall mean any of the events listed in Section 5(a) of this Disclosure Agreement.
“MSRB” shall mean the Municipal Securities Rulemaking Board established pursuant to Section 15B(b)(1) of the Securities Exchange Act of 1934 or any other entity designated or authorized by the Securities and Exchange Commission to receive reports pursuant to the Rule. Until Packet Pg. 461 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) E-3
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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” shall mean the Official Statement dated [_______], 2026, relating to the Bonds.
“Participating Underwriter” shall mean any of the original underwriter of the Bonds listed on the cover page of the Official Statement required to comply with the Rule in connection with offering of the Bonds.
“Rule” shall mean Rule 15c2-12(b)(5) adopted by the SEC under the Securities Exchange Act of 1934, as the same may be amended from time to time. “SEC” shall mean the United States Securities and Exchange Commission.
Provision of Annual Reports.
The City shall, or shall cause the Dissemination Agent to, not later than 270 days after the end of the City’s Fiscal Year (which Fiscal Year presently ends on June 30), commencing with the report for the 2025-26 Fiscal Year, provide to the MSRB an Annual Report which is consistent with the requirements of Section 4 of this Disclosure Agreement. The Annual Report must be submitted in electronic format, accompanied by such identifying information as prescribed by the MSRB. The Annual Report may be submitted as a single document or as separate documents comprising a package, and may cross-reference other information as provided in Section 4 of this Disclosure Agreement; provided that if the audited financial statements of the City’s Electric Utility Fund are not available by the date required above for the filing of the Annual Report, the City shall submit the audited financial statements as soon thereafter as available. If the City’s Fiscal Year changes, it shall give notice of such change in the same manner as for a Listed Event under Section 5.
If the City is unable to provide to the MSRB an Annual Report by the date required in subsection (a), the City shall, or shall cause the Dissemination Agent to, send to the MSRB a notice in substantially the form attached hereto as Exhibit A.
The Dissemination Agent shall:
determine the electronic filing address of, and then-current procedures for submitting Annual Reports to, the MSRB each year prior to the date for providing the Annual Report; and
file a report with the City and (if the Dissemination Agent is not the Trustee, the Trustee) certifying that the Annual Report has been provided to the MSRB pursuant to this Disclosure Agreement, and stating the date it was provided.
Content of Annual Reports. The City’s Annual Report shall contain or include by reference the following categories or similar categories of information updated to incorporate information for the most recent Fiscal Year (the tables referred to below are those appearing in the Official Statement relating to the Bonds):
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The audited financial statements of the City’s Electric Utility Fund (which may be included as a component of the City’s city-wide audited financial statements) for the most recently completed Fiscal Year, prepared in accordance with generally accepted accounting principles for governmental enterprises as prescribed from time to time by any regulatory body with jurisdiction over the City and by the Governmental Accounting Standards Board. If the City’s Electric Utility Enterprise Fund audited financial statements are not available by the time the Annual Report is required to be filed pursuant to Section 3(a), the Annual Report shall contain unaudited financial statements in a format similar to the audited financial statements, and the audited financial statements shall be filed in the same manner as the Annual Report when they become available.
Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT POWER SUPPLY RESOURCES” as it appears in the Official Statement;
Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT CUSTOMERS, SALES, REVENUES AND DEMAND” as it appears in the Official Statement; Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT SUMMARY OF OPERATING RESULTS” as it appears in the Official Statement; and Updated information comparable to the information in the table entitled “CITY OF REDDING ELECTRIC UTILITY DEPARTMENT OUTSTANDING DEBT OF JOINT POWERS AGENCIES” as it appears in the Official Statement.
Financial and operating information relating to the City referenced in items (ii)-(v) above may be updated from time to time, and such updates may involve displaying data in a different format or eliminating data that is no longer material.
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 City or related public entities, which have been submitted to the MSRB or the SEC. If any document included by reference is a final official statement, it must be available from the MSRB. The City shall clearly identify each such other document so included by reference.
Reporting of Listed Events.
(a) Pursuant to the provisions of this Section 5, upon the occurrence of any of the following events (in each case to the extent applicable) with respect to the Bonds, the City shall give, or cause to be given by so notifying the Dissemination Agent in writing and instructing the Dissemination Agent to give, notice of the occurrence of such event, in each case, pursuant to Section 5(c) hereof:
principal or interest payment delinquencies;
non-payment related defaults, if material;
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unscheduled draws on the debt service reserves reflecting financial difficulties; unscheduled draws on the credit enhancements reflecting financial difficulties; substitution of credit or liquidity providers, or their failure to perform; adverse tax opinions or the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701- TEB) or other material notices or determinations with respect to the tax status of the Bonds, or other material events affecting the tax status of the Bonds; modifications to the rights of the Bondholders, if material; optional, contingent or unscheduled calls, if material, and tender offers; defeasances;
release, substitution or sale of property securing repayment of the Bonds, if material; rating changes;
bankruptcy, insolvency, receivership or similar proceedings of the City, which shall occur as described below;
the consummation of a merger, consolidation, or acquisition involving the City or the sale of all or substantially all of the assets of the City’s Electric System other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material; appointment of a successor or additional trustee or the change of name of a trustee, if material;
incurrence of a Financial Obligation of the City with respect to the Electric System, if material, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of the City with respect to the Electric System, any of which affects Holders of the Bonds, if material; or
default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a Financial Obligation of the City with respect to the Electric System, any of which reflect financial difficulties.
For these purposes, (i) any event described in item 12 of this Section 5(a) is considered to occur when any of the following occur: the appointment of a receiver, fiscal agent, or similar officer for the City in a proceeding under the United States Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the City or its Electric System, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of Packet Pg. 464 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) E-6
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reorganization, arrangement, or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the City or its Electric System; and (ii) the City intends to comply with the provisions hereof for the Listed Events described in subparagraphs (15) and (16) of this Section 5(a), and the definition of the “Financial Obligation” in Section 2, with reference to the Rule, any other applicable federal securities laws and guidance provided by the SEC in its Release No. 34-83885 dated August 20, 2018 (the “2018 Release”), any further amendments or written guidance provided by the SEC or its staff with respect to the amendments to the Rule effected by the 2018 Release.
Upon receipt of notice from the City and instruction by the City to report the occurrence of any Listed Event, the Dissemination Agent shall provide notice thereof to the MSRB in accordance with Section 5(c) hereof. In the event the Dissemination Agent shall obtain actual knowledge of the occurrence of any of the Listed Events, the Dissemination Agent shall, immediately after obtaining such knowledge, contact the Disclosure Representative, inform such person of the event, and request that the City promptly notify the Dissemination Agent in writing whether or not to report the event pursuant to Section 5(c). For purposes of this Disclosure Agreement, “actual knowledge” of the occurrence of such Listed Event shall mean actual knowledge by the Dissemination Agent, if other than the Trustee, and if the Dissemination Agent is the Trustee, then by the officer at the corporate trust office of the Trustee with regular responsibility for the administration of matters related to the Indenture. The Dissemination Agent shall have no responsibility to determine the materiality, if applicable, of any of the Listed Events.
The City, or the Dissemination Agent, if the Dissemination Agent has been instructed by the City to report the occurrence of a Listed Event pursuant to Section 5(b), shall file a notice of the occurrence of any of the events listed in Section 5(a) hereof with the MSRB in a timely manner not more than ten (10) business days after the occurrence of the event.
Termination of Reporting Obligation. The City’s obligations under this Disclosure Agreement shall terminate with respect to all Bonds upon the maturity, legal defeasance, prior redemption or payment in full of all of the Bonds and with respect to any Bonds upon the maturity, defeasance, prior redemption or payment in full of such Bonds.
Dissemination Agent. The City 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. If at any time there is not any other designated Dissemination Agent, the Trustee, upon notice from the City, shall be the Dissemination Agent. The initial Dissemination Agent shall be the Trustee. The Dissemination Agent shall not be responsible in any manner for the content of any notice or report prepared by the City pursuant to this Disclosure Agreement. The Dissemination Agent shall receive compensation for the services provided pursuant to this Disclosure Agreement.
Amendment; Waiver. Notwithstanding any other provision of this Disclosure Agreement, the City and the Dissemination Agent may amend this Disclosure Agreement, (and, to the extent that any such amendment does not materially change or increase its obligations hereunder, the Dissemination Agent shall agree to any amendment so requested by the City), and any provision of this Disclosure Agreement may be waived; provided, that the following conditions are satisfied:
If the amendment or waiver relates to the provisions of Section 3(a), Section 4 or Section 5(a), it may only be made in connection with a change in circumstances that arises from a Packet Pg. 465 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) E-7
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change in legal requirements, change in law, or change in the identity, nature or status of an obligated person with respect to the Bonds, or the type of business conducted; 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 issuance of the Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; and The amendment or waiver does not, in the opinion of nationally recognized bond counsel, materially impair the interests of the Holders or Beneficial Owners of the Bonds.
In the event of any amendment or waiver of a provision of this Disclosure Agreement, the City shall describe such amendment in the next Annual 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 City. In addition, if the amendment relates to the accounting principles to be followed in preparing financial statements, (i) notice of such change shall be given in the same manner as for a Listed Event under Section 5(c), and (ii) the Annual Report for the year in which the change is made should 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.
Filings with the MSRB. All information, operating data, financial statements, notices and other documents provided to the MSRB in accordance with this Disclosure Agreement shall be provided in an electronic format prescribed by the MSRB and shall be accompanied by identifying information as prescribed by the MSRB.
Additional Information. Nothing in this Disclosure Agreement shall be deemed to prevent the City 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 Report or notice of occurrence of a Listed Event, in addition to that which is required by this Disclosure Agreement. If the City chooses to include any information in any Annual Report or notice of occurrence of a Listed Event in addition to that which is specifically required by this Disclosure Agreement, the City shall have no obligation under this Disclosure Agreement to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event.
Default. In the event of a failure of the City or the Dissemination Agent to comply with any provision of this Disclosure Agreement, the Trustee may (and, at the request of any Participating Underwriter or the Holders of at least 25% of the aggregate principal amount of Outstanding Bonds and upon provision of indemnification satisfactory to the Trustee, shall), or any Holder or Beneficial Owner of the Bonds may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the City or the Dissemination Agent, as the case may be, to comply with its obligations under this Disclosure Agreement. A default under 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 City or the Dissemination Agent to comply with this Disclosure Agreement shall be an action to compel performance hereunder.
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Duties, Immunities and Liabilities of Trustee and Dissemination Agent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Agreement, and the City 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 attorneys’ fees) of defending against any claim of liability, but excluding any loss, expense and liabilities due to the Dissemination Agent’s negligence or willful misconduct. The obligations of the City under this Section 12 shall survive resignation or removal of the Dissemination Agent and payment of the Bonds.
Notices. Any notices or communications to or among any of the parties to this Disclosure Agreement may be given as follows:
To the City: To the Dissemination Agent:
City of Redding
777 Cypress Avenue
Redding, California 96001
Attention: Finance Officer
Phone: (530) 225-4087
Fax: (530) 225-4324
U.S. Bank Trust Company, National Association
One California Street, Suite 1000
San Francisco, California 94111
Attention: Global Corporate Trust Services
Phone: (415) 677-3597
Fax: (415) 677-3769
Beneficiaries. This Disclosure Agreement shall inure solely to the benefit of the City, the Trustee, the Dissemination Agent, the Participating Underwriter and the Holders and Beneficial Owners from time to time of the Bonds, and shall create no rights in any other person or entity. [Remainder of page intentionally left blank.]
Packet Pg. 467 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) E-9
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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 REDDING, CALIFORNIA
By
City Manager
U.S. BANK TRUST COMPANY,
NATIONAL ASSOCIATION,
as Dissemination Agent
By
Authorized Officer
ACKNOWLEDGED:
U.S. BANK TRUST COMPANY,
NATIONAL ASSOCIATION, as Trustee
By
Authorized Officer
Packet Pg. 468 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) E-1
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EXHIBIT A
NOTICE TO MSRB OF FAILURE TO FILE ANNUAL REPORT
Name of Issuer: CITY OF REDDING
Name of Bond Issue: ELECTRIC SYSTEM REFUNDING REVENUE BONDS, SERIES 2026 Date of Issuance: [CLOSING DATE], 2026
NOTICE IS HEREBY GIVEN that the City of Redding, California (the “City”) has not provided an Annual Report with respect to the above-named Bonds as required by Section 5.07 of the Indenture, dated as of April 1, 2026, by and between the City and U.S. Bank Trust Company, National Association, as trustee, and the Continuing Disclosure Agreement, dated [Closing Date], 2026, by and between the City and U.S. Bank Trust Company, National Association, as Dissemination Agent. The City anticipates that the Annual Report will be filed by ___________, 20__.
Dated: ______________, 20__
U.S. BANK TRUST COMPANY, NATIONAL
ASSOCIATION, as Dissemination Agent on behalf of
the City of Redding
By:
Authorized Officer
cc: City of Redding, California
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APPENDIX F
PROPOSED FORM OF OPINION OF BOND COUNSEL
April [__], 2026
City of Redding
Redding, California
City of Redding
Electric System Refunding Revenue Bonds, Series 2026
(Final Opinion)
Ladies and Gentlemen:
We have acted as bond counsel to the City of Redding (the “City”) in connection with the issuance of $[Series 2026 Par] aggregate principal amount of City of Redding Electric System Refunding Revenue Bonds, Series 2026 (the “Bonds”), issued pursuant to an indenture, dated as of April 1, 2026 (the “Indenture”), between the City and U.S. Bank Trust Company, National Association, as trustee (the “Trustee”). Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the Indenture.
In such connection, we have reviewed the Indenture, the Tax Certificate, dated the date hereof (the “Tax Certificate”), opinions of counsel to the City and the Trustee, certificates of the City, the Trustee and others, and such other documents, opinions and matters to the extent we deemed necessary to render the opinions set forth herein.
The opinions expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such opinions may be affected by actions taken or omitted or events occurring after original delivery of the Bonds on the date hereof. We have not undertaken to determine, or to inform any person, whether any such actions are taken or omitted or events do occur or any other matters come to our attention after original delivery of the Bonds on the date hereof. Accordingly, this letter speaks only as of its date and is not intended to, and may not, be relied upon or otherwise used in connection with any such actions, events or matters. Our engagement with respect to the Bonds has concluded with their issuance, and we disclaim any obligation to update this letter. We have assumed that each document and each signature thereon provided to us is genuine and that each such document has been duly and legally executed by, and constitutes a valid and binding agreement of, each party thereto other than the City. We have assumed, without undertaking to verify, the accuracy of the factual matters represented, warranted or certified in the documents and of the legal conclusions contained in the opinions, referred to in the second paragraph hereof. Furthermore, we have assumed compliance with all covenants and agreements contained in the Indenture and the Tax Certificate, including (without limitation) covenants and agreements compliance with which is necessary to assure that future actions, omissions or events will not cause interest on the Bonds to be included in gross income for federal income tax purposes. We call attention to the fact that the rights and obligations under the Bonds, the Indenture and the Tax Certificate and their enforceability may be subject to bankruptcy, insolvency, receivership, reorganization, arrangement, fraudulent conveyance, Packet Pg. 470 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A) F-2
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moratorium and other laws relating to or affecting creditors’ rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against governmental entities such as the City in the State of California. We express no opinion with respect to any indemnification, contribution, liquidated damages, penalty (including any remedy deemed to constitute a penalty), right of set-off, arbitration, judicial reference, choice of law, choice of forum, choice of venue, non-exclusivity of remedies, waiver or severability provisions contained in the foregoing documents, nor do we express any opinion with respect to the state or quality of title to or interest in any of the assets described in or as subject to the lien of the Indenture or the accuracy or sufficiency of the description contained therein of, or the remedies available to enforce liens on, any such assets. Our services did not include financial or other non-legal advice.
Finally, we undertake no responsibility for the accuracy, completeness or fairness of the Official Statement or other offering material relating to the Bonds and express no view with respect thereto.
Based on and subject to the foregoing, and in reliance thereon, as of the date hereof, we are of the following opinions:
1. The Bonds constitute the valid and binding special obligations of the City.
2. The Indenture has been duly executed and delivered by, and constitutes the valid and binding agreement of, the City. The Indenture creates a valid pledge, to secure the payment of the principal of and interest on the Bonds, of the Net Revenues of the Electric System and moneys in the City’s Electric Revenue Fund, subject to the provisions of the Indenture permitting the application thereof for the purposes and on the terms and conditions set forth in the Indenture.
3. Interest on the Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 and is exempt from State of California personal income taxes. Interest on the Bonds is not a specific preference item for purposes of the federal individual alternative minimum tax. We observe that interest on the Bonds included in adjusted financial statement income of certain corporations is not excluded from the federal corporate alternative minimum tax. We express no opinion regarding other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the Bonds.
Faithfully yours,
ORRICK, HERRINGTON & SUTCLIFFE LLP
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APPENDIX G
DEBT SERVICE SCHEDULE
Fiscal Year Outstanding Parity Obligations(1) 2026 Bonds Total Debt Ending June 30 Principal Interest Total(2) Principal Interest Total Service(2) 2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036 -- -- --
2037 -- -- --
2038 -- -- --
2039 -- -- --
2040 -- -- --
2041 -- -- --
2042 -- -- --
2043 - -- --
2044 -- -- --
2045 -- -- --
2046 -- -- --
2047 -- -- --
2048 -- -- --
2049 -- -- --
2050 -- -- --
2051 -- -- --
2052 -- -- --
2053 -- -- --
2054 -- -- --
2055 -- -- --
Total(2)
__________________
(1) Excludes the installment sale payments relating to the Refunded 2015A Bonds. Includes the 2017 City Electric System Refunding Bonds, the 2018 City Electric System Refunding Bonds and the installment sale payments relating to outstanding 2025 Authority Electric System Bonds. Excludes obligations payable with respect to joint powers agency obligations described under “SECURITY AND SOURCES OF PAYMENT FOR THE 2026 BONDS – Outstanding Electric System Revenue Obligations – Take-or-Pay; Joint Powers Agency Obligations,” which constitute Maintenance and Operation Costs.
(2) Totals may not add due to rounding.
Packet Pg. 472 Attachment: Official Statement (9.5(b)--Consider Authorization of Bond Refunding 2015A)
CITY OF REDDING
REPORT TO THE CITY COUNCIL
Recommendation
Authorize and approve the following:
(1) Accept an informational report regarding the impacts of Senate Bill 707 (Open Meetings:
meeting and teleconferencing requirements) relating to the Ralph M. Brown Act, Government Code section 54952.2, et. seq.; and
(2) Adopt Resolution creating City Council Policy No. 223 - Technology Disruption Policy, pursuant to requirements of SB 707, Government Code § 54953.4.(b)(1)(A)(i)(I)(ia).
Fiscal Impact
There is no fiscal impact with this report.
Alternative Action
The City Council could choose to not accept this report, and therefore would not be in compliance with Government Code § 54953.4.(b)(1)(A)(i)(1)(ia).
Background/Analysis
Senate Bill 707 (SB 707) was signed into law on October 3, 2025, and introduces important updates to the Ralph M. Brown Act (Brown Act). SB 707 is intended to modernize public meeting requirements and improve public engagement and accessibility for communities; however, the bill presents local agencies with important considerations regarding implementation logistics and resource planning as it places new restrictions, expectations and duties upon “eligible legislative bodies” which is defined as any of the following: (1) a City Council of a city with a population of 30,000 or more; (2) a Board of Supervisors of a county, or a city and county, with a population of 30,000 or more; (3) a City Council of a city located in a county with a population of 600,000 or more; and (4) a Board of Directors of large special districts meeting certain thresholds based on boundary areas, population, number of employees and/or revenues.
MEETING DATE: June 2, 2026
ITEM NO. 9.12(c)
FROM:
***APPROVED BY***
[email protected] [email protected]
SUBJECT: 9.12(c)--Consider report regarding impacts of Senate Bill (SB) 707 regarding updates to the Ralph M. Brown Act effective July 1, 2026.
Sharlene Tipton, City Clerk
Packet Pg. 473
Report to Redding City Council May 28, 2026
Re: 9.12(c)--Report re: impacts of SB 707 regarding updates to Ralph M. Brown Act effective July 1, 2026 Page 2
Redding City Council qualifies as an “eligible legislative body” as the City Council is the governing body of a City with a population of 30,000 or more.
Remote Public Access and Participation Requirements
The new law requires eligible legislative bodies to offer participation and attendance through a two-way phone or video platform and requires the adoption of disruption procedures. On or before July 1, 2026, an eligible legislative body must adopt a policy governing disruption of telephonic and internet service for remote participants. Such a policy must be adopted by a separate majority vote, not on the Consent Calendar, of the eligible legislative body in an open session. The policy must contain procedures for recessing and reconvening a meeting in the event of disruption and specify the efforts that the eligible legislative body will make to attempt to restore the service for persons participating remotely. These requirements include recessing the open session and making a good-faith attempt to restore the service disruption of telephonic or internet services that prevents the public from attending or observing the meeting. The policy must also prohibit the legislative body from reconvening the open session of the meeting until at least one hour following the disruption, or until telephonic or internet service is restored, whichever is earlier. Council Policy No. 223 (Technology Disruption Policy) is attached for the Council’s review as Exhibit A. SB 707 authorizes removal of virtual attendees causing disruption under the Brown Act. The City must still provide warning before removal, unless behavior constitutes use of force or true threat of force.
The City has contracted with CityzenSolutions, Inc., dba PublicInput, Inc. to provide two-way telephonic public comment services, with the go-live date anticipated to be July 21, 2026.
PublicInput software allows for receiving and managing requests to speak and public participation through one platform allowing for reduced staff workload. Additionally, the software provides the ability to easily gather metrics on participation. This solution also would not require the need for an additional staff member during meetings.
At this time, PublicInput software has been purchased due to SB 707. It has only been secured for City Council meetings due to financial constraints. It is not a mandate of SB 707 to expand to other Boards/Committees, but can be, should the Council choose to do so. These requirements do not apply to certain specified types of meetings, including meetings held offsite or for inspection purposes, or in emergency situations. The attached policy incorporates all the required provisions noted here.
Language Translation, Interpretation, and Public Participation SB 707 requires translation of agendas and public meetings information webpage into “applicable languages” based on the most recent American Community Survey (ACS) data of the population served. “Applicable languages” are defined as any language spoken jointly by 20 percent or more of an applicable population that speaks English less than “very well” according to ACS data. Staff has reviewed and, based on the criteria, the City of Redding does not meet the 20 percent threshold required for translation.
SB 707 also requires public agencies to reasonably assist any member of the public who wishes to translate a meeting or wishes to receive interpretation provided by another member of the public, so long as the interpretation does not disrupt the meeting. Reasonable assistance may include arranging space for interpreters at the meeting location, allowing extra time during the Packet Pg. 474
Report to Redding City Council May 28, 2026
Re: 9.12(c)--Report re: impacts of SB 707 regarding updates to Ralph M. Brown Act effective July 1, 2026 Page 3
meeting for interpretation or ensuring that participants may use personal equipment or reasonably access commercially available interpretation services. The City of Redding is not required to provide interpretation of meetings but may elect to do so at its discretion.
The City of Redding is also required to provide a physical location for members of the public to post their own additional translations of the agenda in reasonable proximity to the physical location in which Council meeting agendas are posted. Council meeting agendas are posted on locked boards outside of the Council Chambers. Staff have already purchased and installed a two-door enclosed bulletin board with magnets on the outside wall of the Chambers that is freely accessible for the public to provide alternative translations for Council meetings. The City Council is not responsible for the content or accuracy of any translation provided.
In addition to the above, SB 707 requires the City to encourage residents, including those in underrepresented communities and non-English-speaking communities, to participate in public meetings. This includes maintaining a system for electronically accepting and fulfilling requests for meeting agendas and documents through email or through an integrated agenda management platform and maintaining an accessible internet webpage dedicated to public meetings that provides information about public meetings and the steps to participate. Staff currently manage requests for this through the City Council and City Clerk email addresses ([email protected] and [email protected]) and the City Council phone number at (530) 225-4447. Staff are working with the City’s Communications team to update the website to comply with SB 707 requirements.
This report is an informational report and is not all inclusive of all of the changes to the Brown Act. Government Code Sections 54952.2 et. Seq. is attached to this staff report for reference.
Environmental Review
This is not a project defined under the California Environmental Quality Act, and no further action is required.
Council Priority/City Manager Goals
• Communication and Transparency – “Improve the quality of communication with the public and City employees to enhance knowledge and increase transparency to improve public trust.”
• Government of the 21st Century – “Be relevant and proactive to the opportunities and challenges of today’s residents and workforce. Anticipate the future to make better decisions today.”
Attachments
Resolution - SB 707 Technology Disruption Policy
Exhibit A - Council Policy No. 223 - Technology Disruption Policy (SB 707) Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ Packet Pg. 475
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RESOLUTION NO. 2026-___
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDDING ADOPTING CITY COUNCIL POLICY NO. 223, TECHNOLOGY
DISRUPTION POLICY FOR CITY COUNCIL MEETINGS
WHEREAS, on October 3, 2025, Governor Newsom signed into law Senate Bill 707 (“SB 707”), the Brown Act Modernization Act, which requires eligible legislative bodies provide members of the public an opportunity to attend open and public meetings through a two-way telephonic service or a two-way audiovisual platform, subject to the exceptions stated in that section; and WHEREAS, pursuant to Government Code § 54953.4(b)(1)(A)(i)(l)(ia), the City Council must, on or prior to July 1, 2026, adopt a publicly approved policy to address disruption of telephonic or internet service occurring during meetings where remote access is required; and WHEREAS, Government Code section 54953.4, subdivision (b)(1)(A)(i)(I)(ib)–(Ic), establishes requirements for recessing and reconvening a meeting and for making good faith efforts to restore service if a disruption prevents members of the public from attending or observing the meeting remotely; and WHEREAS, the City Council is the City’s only “eligible legislative body” for purposes of Government Code section 54953.4; and
WHEREAS, the attached Technology Disruption Policy ensures compliance with SB 707, if a disruption prevents public members from attending or observing via two-way telephonic service or two-way audiovisual platform, the City Council must recess open session for at least one hour, or until service is restored, whichever is earlier; and
WHEREAS, if after an hour service is not restored, the City Council shall reconvene and either:
1. Adjourn the meeting; or
2. Adopt a finding, by roll call vote, that good faith efforts were made in accordance with the Policy and that the public interest in continuing the meeting outweighs the public interest in remote public access; and
WHEREAS, the City Council desires to adopt a policy that implements, and does not expand upon, the requirements of Government Code section 54953.4;
NOW, THEREFORE, IT IS HEREBY RESOLVED, by the City Council of the City of Redding that City Council Policy No. 223, Technology Disruption, as attached hereto as Exhibit A, is adopted.
I HEREBY CERTIFY that the foregoing resolution was introduced and adopted at a regular meeting of the City Council of the City of Redding on the 2nd day of June, 2026, by the following vote:
AYES: COUNCIL MEMBERS:
NOES: COUNCIL MEMBERS:
ABSENT: COUNCIL MEMBERS:
ABSTAIN: COUNCIL MEMBERS:
______________________________________
MIKE LITTAU, Mayor
ATTEST: FORM APPROVED:
____________________________________ _______________________________________ SHARLENE TIPTON, City Clerk BENJAMIN L STOCK, Interim City Attorney Packet Pg. 476 Attachment: Resolution - SB 707 Technology Disruption Policy (9.12(c)--Report re: impacts of SB 707 regarding updates to Ralph M. Brown Act Policy History: Adopted 06.02.26. Effective 07.01.26.
Lead Department: Office of the City Clerk
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EXHIBIT A
Technology Disruption Policy
Policy No.: 223
Resolution No.: N/A
Effective Date: 07.01.2026
Type: City Council
1. Background
Senate Bill 707 (2025) (“SB 707”) amended the Brown Actto require all “eligible legislative bodies” to offer remote public access for City Council meetings through either (1) two-way telephonic service or (2) two-way audiovisual platforms. The City of Redding (the “City”) is an “eligible legislative body” and is required to adopt, on or before July 1, 2026, a policy on how to address telephonic or internet service connection disruption that prevent members of the public from remotely attending or observing a public open meeting of the City Council .
2. Purpose
The purpose of this policy is for the City to establish procedures for responding to a disruption in the telephonic or internet services that provide two-way remote access for the public to attend and participate in public open meetings of City Council, as required by the Brown Act (Gov.
Code § 54953.4). This policy is adopted to ensure statutory compliance, transparency, public participation and access, and continuity of government operation during technology disruptions that occur in public open meetings of the City Council.
3. Definitions
For purposes of this policy:
• “Disruption” means any failure, outage, or other interruption in the City’s telephonic or internet service that prevents members of the public from attending or observing public open meeting of the City Council.
• “Remote Access Services” meansthe two-way telephonic service and/or two-way audiovisual platform used to provide real-time remote public attendance and observation of public open meetings of the City Council.
4. Applicability
This policy applies to all open and public meetings of City Council at which remote public participation is required per Government Code § 54953.4(b)(1)(A)(i)(I)(ia) but does not apply in those circumstances where the Brown Act provides that remote public access is not required.
Packet Pg. 477 Attachment: Exhibit A - Council Policy No. 223 - Technology Disruption Policy (SB 707) (9.12(c)--Report re: impacts of SB 707 regarding Policy History: Adopted 06.02.26. Effective 07.01.26.
Lead Department: Office of the City Clerk
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EXHIBIT A
Technology Disruption Policy
Policy No.: 223
Resolution No.: N/A
Effective Date: 07.01.2026
Type: City Council
5. Procedures in the Event of a Service Disruption
5.1 Response to Service Disruption
If the Presiding Officer or City Clerk becomes aware of a disruption to the City’s Remote Access Services that prevents members of the public from attending or observing the meeting remotely:
1. The Presiding Officer or City Clerk shall immediately announce the disruption to the public;
2. The Presiding Officer must either adjourn the open session or recess from open session for at least one (1) hour to make a good faith effort to restore the Remote Access Services;
3. If recessed from open session, then City Council may meet in closed session as permitted by Government Code section 54953.4;
4. If recessed from open session, staff shall begin efforts to diagnose and restore the Remote Access Services.
5. If following recess of the open session, Remote Access Services have not been restored within (1) hour, then City Council may reconvene the meeting if it adopts, by roll call vote, a finding required by Section 6.2. The recess period may be extended if restoration efforts are ongoing.
5.2 Efforts to Restore Remote Access Services
The City shall make good faith efforts to restore Remote Access Services, which may include:
• Troubleshooting platform or teleconferencing software; • Resetting or replacing audiovisual equipment;
• Attempting alternative connection methods;
• Contacting necessary support staff or service providers; or • Switching to back-up equipment or platforms, if available Pursuant to Section 7 of this policy, the City Clerk, or designee, shall make a record and enter into the meeting minutes the disruption and the restoration efforts undertaken by the City.
Packet Pg. 478 Attachment: Exhibit A - Council Policy No. 223 - Technology Disruption Policy (SB 707) (9.12(c)--Report re: impacts of SB 707 regarding Policy History: Adopted 06.02.26. Effective 07.01.26.
Lead Department: Office of the City Clerk
3 of 3
4930-1930-1296 v1
EXHIBIT A
Technology Disruption Policy
Policy No.: 223
Resolution No.: N/A
Effective Date: 07.01.2026
Type: City Council
6. Reconvening the Open Session
6.1. Timing
The open session may reconvene either upon restoration of Remote Access Services or after one (1) hour has elapsed from the time of disruption, and the finding required by Section 6.2 of this policy has been adopted by City Council.
6.2 If Remote Access Services Are Not Restored
If Remote Access Services have not been restored after one (1) hour, the City Council may either adjourn open session or reconvene open session only after the following, or a substantially similar finding can be made and is adopted by a roll call vote of the City Council:
“The City Council of the City of Redding has made good faith efforts to restore telephonic or internet service in accordance with its adopted policy and the public interest in continuing the meeting outweighs the public interest in remote public access.” Upon adoption of the finding, the City Council may continue the open session despite the fact that Remote Access Services have not been restored.
7. Recordkeeping
If Remote Access Services were disrupted, then the City Clerk shall make a record and enter into the meeting minutes the following:
• The nature and time of the disruption;
• How the City Council complied with the procedures pursuant to Section 5.1; • The restoration efforts undertaken;
• The time the meeting was reconvened (if applicable); and • The finding adopted pursuant to Section 6.2 (if applicable).
8. Review and Updates
This policy, like other City Council policies, may be reviewed and amended from time-to-time by the City Council. As expressly required by the Brown Act, amendments to this policy must be approved at a properly noticed public meeting in open session and may not be approved on the consent calendar.
Packet Pg. 479 Attachment: Exhibit A - Council Policy No. 223 - Technology Disruption Policy (SB 707) (9.12(c)--Report re: impacts of SB 707 regarding SHARE THIS: Date Published: 10/06/2025 02:00 PM
SB-707 Open meetings: meeting and teleconference requirements. (2025-2026) Senate Bill No. 707
CHAPTER 327
An act to amend Sections 54952.7, 54953, 54953.5, 54953.7, 54954.2, 54954.3, 54956, 54956.5, 54957.6, 54957.9, and 54957.95 of, to amend and repeal Section 54952.2 of, to add Sections 54953.8, 54953.8.1, 54953.8.2, and 54957.96 to, and to add and repeal Sections 54953.4, 54953.8.3, 54953.8.4, 54953.8.5, 54953.8.6, and 54953.8.7 of, the Government Code, relating to local government.
[ Approved by Governor October 03, 2025. Filed with Secretary of State October 03, 2025. ]
LEGISLATIVE COUNSEL'S DIGEST
SB 707, Durazo. Open meetings: meeting and teleconference requirements. (1) Existing law, the Ralph M. Brown Act, requires, with specified exceptions, that all meetings of a legislative body, as defined, of a local agency be open and public and that all persons be permitted to attend and participate.
This bill would, beginning July 1, 2026, and until January 1, 2030, require an eligible legislative body, as defined, to comply with additional meeting requirements, including that, except as specified, all open and public meetings include an opportunity for members of the public to attend via a 2-way telephonic service or a 2-way audiovisual platform, as defined, and that the eligible legislative body take specified actions to encourage residents to participate in public meetings, as specified. The bill would require an eligible legislative body, on or before July 1, 2026, to approve at a noticed public meeting in open session a policy regarding disruption of telephonic or internet services occurring during meetings subject to these provisions, as specified, and would require the eligible legislative body to comply with certain requirements relating to disruption, including for certain disruptions, recessing the open session for at least one hour and making a good faith attempt to restore the service, as specified.
(2) Existing law prohibits a majority of the members of a legislative body, outside a meeting authorized by the act, from using a series of communications of any kind to discuss, deliberate, or take action on any item of business that is within the subject matter jurisdiction of the legislative body. Existing law defines “meetings” for these purposes to mean any congregation of a majority of the members of a legislative body at the same time and location, as specified, to hear, discuss, deliberate, or take action on any item that is within the subject matter jurisdiction of the legislative body. Until January 1, 2026, existing law excepts from the prohibition a member engaging in separate conversations or communications outside of a meeting with any other person using an internet-based social media platform for specified purposes, provided, among other things, that a Home Bill Information California Law Publications Other Resources My Subscriptions My Favorites 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 1/25 Packet Pg. 480 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding majority of the members do not use the internet-based social media platform to discuss among themselves business of a specific nature that is within the subject matter jurisdiction of the legislative body.
This bill would make the above-described exception related to communications on an internet-based social media platform applicable indefinitely.
(3) Existing law requires a legislative body, prior to taking final action, to orally report a summary of a recommendation for a final action on specified forms of compensation for a local agency executive, as defined, during the open meeting in which the final action is to be taken.
This bill would also require the legislative body to make that oral report, as provided above, prior to taking final action on those specified forms of compensation for a department head or other similar administrative officer of the local agency.
(4) Existing law requires a legislative body of a local agency or its designee, at least 72 hours before a regular meeting, to post an agenda that meets specified requirements, including that the agenda contain a brief general description of each item of business to be transacted or discussed at the meeting, as specified.
This bill would, beginning July 1, 2026, and until July 1, 2030, require the agenda for each meeting of an eligible legislative body, as defined, to be translated into all applicable languages. The bill would define “applicable languages” to mean languages, according to data from the most recent American Community Survey, spoken jointly by 20% or more of the applicable population, as specified, provided that 20% or more of the population that speaks that language that in that city or county speaks English less than “very well,” as specified, and except as provided.
Existing law requires every agenda for regular meetings to provide an opportunity for members of the public to directly address the legislative body on any item of interest of the public, as specified. Existing law specifies that the agenda is not required to provide an opportunity for members of the public to address the legislative body on any item that has already been considered by a committee, as specified, except if the item has been substantially changed since the committee heard the item, as determined by the legislative body.
This bill would add certain exceptions to the provision related to an item that has already been considered by a committee, including excepting committees whose primary subject matter jurisdiction focuses on elections, budgets, police oversight, privacy, removing from, or restricting access to, materials available in public libraries, or taxes or related spending proposals, except as specified. (5) Existing law authorizes a legislative body of a local agency to require a copy of the act to be given to each member of the legislative body and specified persons elected to serve as a member of the legislative body, and authorizes an elected legislative body member to require a copy to be given to each member of each legislative body all or a majority of whose members are appointed by or under the authority of the elected legislative body.
This bill would instead require a local agency to provide a copy of the act to any person elected or appointed to serve as a member of a legislative body of the local agency.
Existing law authorizes legislative bodies of local agencies to impose requirements upon themselves which allow greater access to their meetings than prescribed by the minimal standards set forth in the act, and authorizes an elected legislative body of a local agency to also impose those requirements on those appointed legislative bodies of the local agency of which all or a majority of the members are appointed by or under the authority of the elected legislative body.
This bill would remove the above-described requirement that members of an appointed legislative body of a local agency must be appointed by or under the authority of the elected legislative body of a local agency in order for the elected legislative body to impose the above-described requirements on the appointed legislative body. (6) Existing law provides any person attending an open and public meeting of a legislative body of a local agency with the right to record the proceedings with an audio or visual recorder or a still or motion picture camera, as specified.
This bill would remove the reference to an audio or visual recorder or a still or motion picture camera for purposes of recording the proceedings, as described above. (7) Existing law authorizes a legislative body of a local agency to use teleconferencing, as specified, and requires a legislative body of a local agency that elects to use teleconferencing to comply with specified general requirements, including that the local agency post agendas at all teleconference locations, identify each 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 2/25 Packet Pg. 481 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding teleconference location in the notice and agenda of the meeting or proceeding, and have each teleconference location be accessible to the public. Existing law also requires that, during the teleconference, at least a quorum of the members of the legislative body participate from locations within the boundaries of the territory over which the local agency exercises jurisdiction, except as specified.
Existing law authorizes members who are outside the jurisdiction of a health authority, as defined, that conducts a teleconferencing meeting to, notwithstanding the above-described general teleconference provisions, count towards the establishment of a quorum when participating in the teleconference if, among other things, at least 50% of the number of members that would establish a quorum are present within the boundaries of the territory over which the authority exercises jurisdiction.
Existing law authorizes, in certain circumstances, the legislative body of a local agency to use specified alternative teleconferencing which include provisions related to, among others, notice of the means by which members of the public may access the meeting and offer public comment and identifying and including an opportunity for all persons to attend via a call-in option or an internet-based service option. Those circumstances in which the legislative body of a local agency is authorized to use the alternative teleconferencing provisions include specified circumstances relating to a state of emergency, as defined, and, until January 1, 2026, subject to specified limitations, a member’s need to participate remotely due to just cause, defined to include, among other things, a need related to a physical or mental disability, or emergency circumstances, as defined, if certain quorum and disclosure requirements are met.
Existing law also authorizes certain eligible legislative bodies, including neighborhood councils and student body associations and student-run community college organizations to, until January 1, 2026, use alternate teleconferencing if, among other requirements, the city council or board of trustees, as applicable, has adopted an authorizing resolution and 2
/3 of the neighborhood city council or specified student organization, as applicable, votes to use alternate teleconference provisions, as specified.
This bill would revise and recast the above-specified teleconferencing and alternative teleconferencing provisions to uniformly apply certain noticing, disclosure, accessibility, and public commenting provisions. The bill would require a legislative body of a local agency that elects to use teleconferencing pursuant to these alternative teleconferencing provisions to comply with, in addition to any other applicable requirements under the act, specified requirements, including that the legislative body provides at least either 2-way audiovisual platform or 2-way telephonic service and a live webcasting of the meeting as a means by which the public may, among other things, remotely hear and visually observe the meeting, and that a member of the legislative body who participates in a teleconference meeting from a remote location pursuant to these alternative teleconferencing provisions and the specific provision of law that the member relied upon to permit their participation by teleconferencing are listed in the minutes of the meeting. The bill would require a local agency to identify and make available to legislative bodies a list of one or more meeting locations that may be available for use by the legislative bodies to conduct their meetings.
The bill would specify that nothing in the bill’s provisions is to be construed to prohibit a member of a legislative body with a disability, as defined, from participating in any meeting of the legislative body by remote participation as a reasonable accommodation pursuant to any applicable law. The bill would apply certain provisions relative to, among other things, quorum establishment to that circumstance.
The bill would instead authorize a health authority, as defined, to conduct a teleconference meeting pursuant to the above-described alternative teleconferencing provisions.
The bill would revise and recast the alternative teleconferencing provisions applicable in a state of emergency, as defined. The bill would also include a local emergency, as defined, as a circumstance in which a legislative body of a local agency is authorized to use the alternative teleconferencing provisions.
The bill would revise and recast the alternative teleconferencing provisions applicable in cases of a member’s need to participate remotely due to just cause or emergency circumstances, as defined, to remove the provision applicable to emergency circumstances, to revise related definitions, including broadening the definition of just cause to include, among other things, a physical or family medical emergency that prevents a member from attending in person, and to require the minutes for a meeting to identify the specific provision of law that each member relied upon to participate remotely, as specified. The bill would extend the authorization to use the alternative teleconferencing provision until January 1, 2030.
The bill would revise and recast the alternative teleconferencing provisions applicable to neighborhood councils and student body associations and student-run community college organizations. In regards to the alternative 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 3/25 Packet Pg. 482 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding teleconferencing provisions applicable to student body associations and student-run community college organizations, the bill would exempt the California Online Community College from specified requirements for an in-person quorum, a physical location for public participation, and certain accommodations under the authorization, and remove the ability for a person with a disability that requires certain accommodations to count towards the in-person quorum requirement. The bill would specify that the student body associations and student-run community college organizations described above are those in any community college recognized within the California Community Colleges system, and would extend the authorization to the Student Senate for California Community Colleges. The bill would extend the authorization to use the alternative teleconferencing provisions applicable to neighborhood councils and student body associations and student-run community college organizations until January 1, 2030.
The bill would, until January 1, 2030, also authorize a specified subsidiary body of local agencies to conduct a teleconference meeting pursuant to the above-described alternative teleconferencing provisions, provided that it complies with the requirements for alternative teleconferencing described above and additional requirements, including that the subsidiary body designates one physical meeting location within the boundaries of the legislative body that created the subsidiary body where members of the subsidiary body who are not participating remotely shall be present and members of the public may physically attend, observe, hear, and participate in the meeting, as specified.
The bill would, until January 1, 2030, also authorize specified multijurisdictional bodies of local agencies to conduct a teleconference meeting pursuant to the above-described alternative teleconferencing provisions, provided that it complies with the requirements for alternative teleconferencing described above and additional requirements, including that the eligible multijurisdictional body has adopted a resolution that authorizes the multijurisdictional body to use teleconferencing at a regular meeting in open session.
The bill would specify that these teleconferencing provisions are cumulative, and would authorize a legislative body to elect to use any teleconferencing provisions that are applicable to a meeting, regardless of whether any other teleconferencing provisions would also be applicable to that meeting.
Existing law defines “teleconference” for purposes of the authorization for a legislative body of a local agency to use teleconferencing to mean a meeting of a legislative body, the members of which are in different locations, connected by electronic means, through either audio or video, or both.
This bill would specify that “teleconference” does not include the attendance of one or more members of a legislative body in a meeting of the body solely by watching or listening via webcasting or any other similar electronic medium that does not permit members to interactively speak, discuss, or deliberate on matters. (8) Existing law authorizes a special meeting to be called any time by, among other persons, the presiding officer of the legislative body of a local agency, by delivering specified written notices and posting a notice on the local agency’s internet website, if the local agency has one. Existing law requires specified legislative bodies to comply with the internet website posting requirement.
The bill would remove the requirement that only specified legislative bodies comply with the internet website posting requirement, thereby imposing that requirement on all legislative bodies. (9) Existing law authorizes a legislative body of a local agency to hold an emergency meeting without complying with specified notice and posting requirements in the case of emergency circumstances, as specified, and imposes various requirements under these provisions applicable to either legislative bodies generally or legislative bodies which are a school board.
This bill would remove the school board distinction from the above-described provisions, thereby imposing the same requirements to hold an emergency meeting on all legislative bodies of local agencies.
By imposing additional duties on legislative bodies of local agencies, the bill would impose a state-mandated local program.
(10) Existing law authorizes, in addition to other related specified authorizations, the presiding member of the legislative body conducting a meeting or their designee to remove, or cause the removal of, an individual for disrupting the meeting. Existing law defines “disrupting” for these purposes to mean engaging in behavior during a meeting of a legislative body that actually disrupts, disturbs, impedes, or renders infeasible the orderly conduct of the meeting, as specified.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 4/25 Packet Pg. 483 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding This bill would specify that a meeting for purposes of that provision includes any teleconferenced meeting. The bill would specify that the existing authority of a legislative body or its presiding officer to remove or limit participation by persons who engage in behavior that actually disrupts, disturbs, impedes, or renders infeasible the orderly conduct of the meeting, as specified, applies to members of the public participating in a meeting via a 2-way telephonic service or a 2-way audiovisual platform, as those terms are defined. (11) The bill would make other updates to references in the act. (12) Existing constitutional provisions require that a statute that limits the right of access to the meetings of public bodies or the writings of public officials and agencies be adopted with findings demonstrating the interest protected by the limitation and the need for protecting that interest.
This bill would make legislative findings to that effect. (13) The California Constitution requires local agencies, for the purpose of ensuring public access to the meetings of public bodies and the writings of public officials and agencies, to comply with a statutory enactment that amends or enacts laws relating to public records or open meetings and contains findings demonstrating that the enactment furthers the constitutional requirements relating to this purpose.
This bill would make legislative findings to that effect. (14) The bill would include findings that changes proposed by this bill address a matter of statewide concern rather than a municipal affair and, therefore, apply to all cities, including charter cities. (15) The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.
This bill would provide that no reimbursement is required by this act for a specified reason.
Vote: majority Appropriation: no Fiscal Committee: yes Local Program: yes THE PEOPLE OF THE STATE OF CALIFORNIA DO ENACT AS FOLLOWS:
SECTION 1. Section 54952.2 of the Government Code, as amended by Section 1 of Chapter 89 of the Statutes of 2020, is amended to read:
54952.2. (a) As used in this chapter, “meeting” means any congregation of a majority of the members of a legislative body at the same time and location, including teleconference location as permitted by Section 54953, to hear, discuss, deliberate, or take action on any item that is within the subject matter jurisdiction of the legislative body.
(b) (1) A majority of the members of a legislative body shall not, outside a meeting authorized by this chapter, use a series of communications of any kind, directly or through intermediaries, to discuss, deliberate, or take action on any item of business that is within the subject matter jurisdiction of the legislative body. (2) Paragraph (1) shall not be construed as preventing an employee or official of a local agency, from engaging in separate conversations or communications outside of a meeting authorized by this chapter with members of a legislative body in order to answer questions or provide information regarding a matter that is within the subject matter jurisdiction of the local agency, if that person does not communicate to members of the legislative body the comments or position of any other member or members of the legislative body. (3) (A) Paragraph (1) shall not be construed as preventing a member of the legislative body from engaging in separate conversations or communications on an internet-based social media platform to answer questions, provide information to the public, or to solicit information from the public regarding a matter that is within the subject matter jurisdiction of the legislative body provided that a majority of the members of the legislative body do not use the internet-based social media platform to discuss among themselves business of a specific nature that is within the subject matter jurisdiction of the legislative body. A member of the legislative body shall not respond directly to any communication on an internet-based social media platform regarding a matter that is within the subject matter jurisdiction of the legislative body that is made, posted, or shared by any other member of the legislative body.
(B) For purposes of this paragraph, all of the following definitions shall apply:
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 5/25 Packet Pg. 484 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (i) “Discuss among themselves” means communications made, posted, or shared on an internet-based social media platform between members of a legislative body, including comments or use of digital icons that express reactions to communications made by other members of the legislative body. (ii) “Internet-based social media platform” means an online service that is open and accessible to the public.
(iii) “Open and accessible to the public” means that members of the general public have the ability to access and participate, free of charge, in the social media platform without the approval by the social media platform or a person or entity other than the social media platform, including any forum and chatroom, and cannot be blocked from doing so, except when the internet-based social media platform determines that an individual violated its protocols or rules. (c) Nothing in this section shall impose the requirements of this chapter upon any of the following:
(1) Individual contacts or conversations between a member of a legislative body and any other person that do not violate subdivision (b).
(2) The attendance of a majority of the members of a legislative body at a conference or similar gathering open to the public that involves a discussion of issues of general interest to the public or to public agencies of the type represented by the legislative body, provided that a majority of the members do not discuss among themselves, other than as part of the scheduled program, business of a specified nature that is within the subject matter jurisdiction of the local agency. Nothing in this paragraph is intended to allow members of the public free admission to a conference or similar gathering at which the organizers have required other participants or registrants to pay fees or charges as a condition of attendance. (3) The attendance of a majority of the members of a legislative body at an open and publicized meeting organized to address a topic of local community concern by a person or organization other than the local agency, provided that a majority of the members do not discuss among themselves, other than as part of the scheduled program, business of a specific nature that is within the subject matter jurisdiction of the legislative body of the local agency.
(4) The attendance of a majority of the members of a legislative body at an open and noticed meeting of another body of the local agency, or at an open and noticed meeting of a legislative body of another local agency, provided that a majority of the members do not discuss among themselves, other than as part of the scheduled meeting, business of a specific nature that is within the subject matter jurisdiction of the legislative body of the local agency.
(5) The attendance of a majority of the members of a legislative body at a purely social or ceremonial occasion, provided that a majority of the members do not discuss among themselves business of a specific nature that is within the subject matter jurisdiction of the legislative body of the local agency. (6) The attendance of a majority of the members of a legislative body at an open and noticed meeting of a standing committee of that body, provided that the members of the legislative body who are not members of the standing committee attend only as observers.
SEC. 2. Section 54952.2 of the Government Code, as added by Section 2 of Chapter 89 of the Statutes of 2020, is repealed.
SEC. 3. Section 54952.7 of the Government Code is amended to read:
54952.7. A local agency shall provide a copy of this chapter to any person elected or appointed to serve as a member of a legislative body of the local agency.
SEC. 4. Section 54953 of the Government Code, as amended by Section 2 of Chapter 534 of the Statutes of 2023, is amended to read:
54953. (a) All meetings of the legislative body of a local agency shall be open and public, and all persons shall be permitted to attend any meeting of the legislative body of a local agency, except as otherwise provided in this chapter.
(b) (1) Notwithstanding any other provision of law, the legislative body of a local agency may use teleconferencing for the benefit of the public and the legislative body of a local agency in connection with any 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 6/25 Packet Pg. 485 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding meeting or proceeding authorized by law. The teleconferenced meeting or proceeding shall comply with all otherwise applicable requirements of this chapter and all otherwise applicable provisions of law relating to a specific type of meeting or proceeding.
(2) Teleconferencing, as authorized by this section, may be used for all purposes in connection with any meeting within the subject matter jurisdiction of the legislative body. If the legislative body of a local agency elects to use teleconferencing, the legislative body of a local agency shall comply with all of the following:
(A) All votes taken during a teleconferenced meeting shall be by rollcall. (B) The teleconferenced meetings shall be conducted in a manner that protects the statutory and constitutional rights of the parties or the public appearing before the legislative body of a local agency. (C) The legislative body shall give notice of the meeting and post agendas as otherwise required by this chapter.
(D) The legislative body shall allow members of the public to access the meeting and the agenda shall provide an opportunity for members of the public to address the legislative body directly pursuant to Section 54954.3.
(3) If the legislative body of a local agency elects to use teleconferencing, it shall post agendas at all teleconference locations. Each teleconference location shall be identified in the notice and agenda of the meeting or proceeding, and each teleconference location shall be accessible to the public. During the teleconference, at least a quorum of the members of the legislative body shall participate from locations within the boundaries of the territory over which the local agency exercises jurisdiction, except as expressly provided in this chapter.
(4) The teleconferencing requirements of this subdivision shall not apply to remote participation described in subdivision (c).
(c) (1) Nothing in this chapter shall be construed to prohibit a member of a legislative body with a disability from participating in any meeting of the legislative body by remote participation as a reasonable accommodation pursuant to any applicable law.
(2) A member of a legislative body participating in a meeting by remote participation pursuant to this subdivision shall do both of the following:
(A) The member shall participate through both audio and visual technology, except that any member with a disability, as defined in Section 12102 of Title 42 of the United States Code, may participate only through audio technology if a physical condition related to their disability results in a need to participate off camera. (B) The member shall disclose at the meeting before any action is taken, whether any other individuals 18 years of age or older are present in the room at the remote location with the member, and the general nature of the member’s relationship with any of those individuals. (3) Remote participation under this subdivision shall be treated as in-person attendance at the physical meeting location for all purposes, including any requirement that a quorum of the legislative body participate from any particular location. The provisions of subdivision (b) and Sections 54953.8 to 54953.8.7, inclusive, shall not apply to remote participation under this subdivision. (d) (1) No legislative body shall take action by secret ballot, whether preliminary or final. (2) The legislative body of a local agency shall publicly report any action taken and the vote or abstention on that action of each member present for the action.
(3) (A) Prior to taking final action, the legislative body shall orally report a summary of a recommendation for a final action on the salaries, salary schedules, or compensation paid in the form of fringe benefits of either of the following during the open meeting in which the final action is to be taken:
(i) A local agency executive, as defined in subdivision (d) of Section 3511.1. (ii) A department head or other similar administrative officer of the local agency. (B) This paragraph shall not affect the public’s right under the California Public Records Act (Division 10 (commencing with Section 7920.000) of Title 1) to inspect or copy records created or received in the 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 7/25 Packet Pg. 486 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding process of developing the recommendation.
(e) For purposes of this section, both of the following definitions apply:
(1) “Disability” means a physical disability or a mental disability as those terms are defined in Section 12926 and used in Section 12926.1, or a disability as defined in Section 12102 of Title 42 of the United States Code. (2) (A) “Teleconference” means a meeting of a legislative body, the members of which are in different locations, connected by electronic means, through either audio or video, or both. (B) Notwithstanding subparagraph (A), “teleconference” does not include one or more members watching or listening to a meeting via webcasting or any other similar electronic medium that does not permit members to interactively speak, discuss, or deliberate on matters. (3) “Remote participation” means participation in a meeting by teleconference at a location other than any physical meeting location designated in the notice of the meeting.
SEC. 5. Section 54953.4 is added to the Government Code, to read:
54953.4. (a) The Legislature finds and declares that public access, including through translation of agendas as required by this section, is necessary for an informed populace. The Legislature encourages local agencies to adopt public access requirements that exceed the requirements of this chapter by translating additional languages, employing human translators, and conducting additional outreach. (b) (1) In addition to any other applicable requirements of this chapter, a meeting held by a eligible legislative body pursuant to this chapter shall comply with both of the following requirements:
(A) (i) (I) (ia) All open and public meetings shall include an opportunity for members of the public to attend via a two-way telephonic service or a two-way audiovisual platform, except if adequate telephonic or internet service is not operational at the meeting location. If adequate telephonic or internet service is operational at the meeting location during only a portion of the meeting, the legislative body shall include an opportunity for members of the public to attend via a two-way telephonic service or a two-way audiovisual platform during that portion of the meeting. (ib) (Ia) On or before July 1, 2026, an eligible legislative body shall approve at a noticed public meeting in open session, not on the consent calendar, a policy regarding disruption of telephonic or internet service occurring during meetings subject to this sub-subclause. The policy shall address the procedures for recessing and reconvening a meeting in the event of disruption and the efforts that the eligible legislative body shall make to attempt to restore the service. (Ib) If a disruption of telephonic or internet service that prevents members of the public from attending or observing the meeting via the two-way telephonic service or two-way audiovisual platform occurs during the meeting, the eligible legislative body shall recess the open session of the meeting for at least one hour and make a good faith attempt to restore the service. The eligible legislative body may meet in closed session during this period. The eligible legislative body shall not reconvene the open session of the meeting until at least one hour following the disruption, or until telephonic or internet service is restored, whichever is earlier. (Ic) Upon reconvening the open session, if telephonic or internet service has not been restored, the eligible legislative body shall adopt a finding by rollcall vote that good faith efforts to restore the telephonic or internet service have been made in accordance with the policy adopted pursuant to sub-sub-subclause (Ia) and that the public interest in continuing the meeting outweighs the public interest in remote public access.
(II) Subclause (I) does not apply to a meeting that is held to do any of the following:
(ia) Attend a judicial or administrative proceeding to which the local agency is a party. (ib) Inspect real or personal property provided that the topic of the meeting is limited to items directly related to the real or personal property.
(ic) Meet with elected or appointed officials of the United States or the State of California, solely to discuss a legislative or regulatory issue affecting the local agency and over which the federal or state officials have jurisdiction.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 8/25 Packet Pg. 487 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (id) Meet in or nearby a facility owned by the agency, provided that the topic of the meeting is limited to items directly related to the facility.
(ie) Meet in an emergency situation pursuant to Section 54956.5. (ii) If an eligible legislative body elects to provide a two-way audiovisual platform, the eligible legislative body shall publicly post and provide a call-in option, and activate any automatic captioning function during the meeting if an automatic captioning function is included with the two-way audiovisual platform.
If an eligible legislative body does not elect to provide a two-way audiovisual platform, the eligible legislative body shall provide a two-way telephonic service for the public to participate in the meeting, pursuant to subclause (I).
(B) (i) All open and public meetings for which attendance via a two-way telephonic service or a two-way audiovisual platform is provided in accordance with paragraph (1) shall provide the public with an opportunity to provide public comment in accordance with Section 54954.3 via the two-way telephonic or two-way audiovisual platform, and ensure the opportunity for the members of the public participating via a two-way telephonic or two-way audiovisual platform to provide public comment with the same time allotment as a person attending a meeting in person.
(2) (A) An eligible legislative body shall reasonably assist members of the public who wish to translate a public meeting into any language or wish to receive interpretation provided by another member of the public, so long as the interpretation is not disrupting to the meeting, as defined in Section 54957.95. The eligible legislative body shall publicize instructions on how to request assistance under this subdivision. Assistance may include any of the following, as determined by the eligible legislative body:
(i) Arranging space for one or more interpreters at the meeting location. (ii) Allowing extra time during the meeting for interpretation to occur. (iii) Ensuring participants may utilize their personal equipment or reasonably access facilities for participants to access commercially available interpretation services. (B) This section does not require an eligible legislative body to provide interpretation of any public meeting, however, an eligible legislative body may elect to provide interpretation of any public meeting. (C) The eligible legislative body is not responsible for the content or accuracy of any interpretation facilitated, assisted with, or provided under this subdivision. An action shall not be commenced or maintained against the eligible legislative body arising from the content or accuracy of any interpretation facilitated, assisted with, or provided under this subdivision. (3) An eligible legislative body shall take the following actions to encourage residents, including those in underrepresented communities and non-English-speaking communities, to participate in public meetings:
(A) Have in place a system for electronically accepting and fulfilling requests for meeting agendas and documents pursuant to Section 54954.1 through email or through an integrated agenda management platform. Information about how to make a request using this system shall be accessible through a prominent direct link posted on the primary internet website home page of the eligible legislative body. (B) (i) Create and maintain an accessible internet webpage dedicated to public meetings that includes, or provides a link to, all of the following information:
(I) A general explanation of the public meeting process for the eligible legislative body. (II) An explanation of the procedures for a member of the public to provide in-person or remote oral public comment during a public meeting or to submit written public comment. (III) A calendar of all public meeting dates with calendar listings that include the date, time, and location of each public meeting.
(IV) The agenda posted online pursuant to paragraph (2) of subdivision (a) of Section 54954.2. (ii) The eligible legislative body shall include a link to the webpage required by subparagraph (A) on the home page of the eligible legislative body’s internet website. 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 9/25 Packet Pg. 488 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (C) (i) Make reasonable efforts, as determined by the legislative body, to invite groups that do not traditionally participate in public meetings to attend those meetings, which may include, but are not limited to, all the following:
(I) Media organizations that provide news coverage in the jurisdiction of the eligible legislative body, including media organizations that serve non-English-speaking communities. (II) Good government, civil rights, civic engagement, neighborhood, and community group organizations, or similar organizations that are active in the jurisdiction of the eligible legislative body, including organizations active in non-English-speaking communities. (ii) Legislative bodies shall have broad discretion in the choice of reasonable efforts they make under this subparagraph. No action shall be commenced or maintained against an eligible legislative body arising from failing to provide public meeting information to any specific group pursuant to this subparagraph. (c) (1) (A) The agenda for each meeting of an eligible legislative body shall be translated into all applicable languages, and each translation shall be posted in accordance with Section 54954.2. Each translation shall include instructions in the applicable language describing how to join the meeting by the telephonic or internetbased service option, including any requirements for registration for public comment. (B) The accessible internet webpage provided under subparagraph (B) of paragraph (3) of subdivision (b) shall be translated into all applicable languages, and each translation shall be accessible through a prominent direct link posted on the primary internet website home page of the eligible legislative body. (2) A translation made using a digital translation service shall satisfy the requirements of paragraph (1). (3) The eligible legislative body shall make available a physical location that is freely accessible to the public in reasonable proximity to the physical location in which the agenda and translations are posted as described in paragraph (1), and shall allow members of the public to post additional translations of the agenda in that location.
(4) The eligible legislative body is not responsible for the content or accuracy of any translation provided pursuant to this subdivision. No action shall be commenced or maintained against an eligible legislative body arising from the content, accuracy, posting, or removal of any translation provided by the eligible legislative body or posted by any person pursuant to this subdivision. (5) For the purposes of this section, the agenda does not include the entire agenda packet. (d) This section shall not be construed to affect or supersede any other applicable civil rights, nondiscrimination, or public access laws.
(e) For purposes of this section, all of the following definitions apply:
(1) (A) “Applicable languages” means languages, according to data from the most recent American Community Survey, spoken jointly by 20 percent or more of the applicable population, provided that 20 percent or more of the population that speaks that language in that city or county speaks English less than “very well.” (B) For the purposes of subparagraph (A), the applicable population shall be determined as follows:
(i) For an eligible legislative body that is a city council or county board of supervisors, the applicable population shall be the population of the city or county. (ii) For an eligible legislative body of a special district, the applicable population shall be either of the following, at the discretion of the board of directors of the special district:
(I) The population of the county with the greatest population within the boundaries of the special district.
(II) The population of the service area of the special district, if the special district has the data to determine what languages spoken by the population within its service area meet the requirements of paragraph (A).
(C) If more than three languages meet the criteria set forth in subparagraph (A), “applicable languages” shall mean the three languages described in subparagraph (A) that are spoken by the largest percentage of the population.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 10/25 Packet Pg. 489 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (D) An eligible legislative body may elect to determine the applicable languages based upon a source other than the most recent American Community Survey if it makes a finding, based upon substantial evidence, that the other source provides equally or more reliable data for the territory over which the eligible legislative body exercises jurisdiction.
(2) “Eligible legislative body” means any of the following:
(A) A city council of a city with a population of 30,000 or more. (B) A county board of supervisors of a county, or city and county, with a population of 30,000 or more. (C) A city council of a city located in a county with a population of 600,000 or more. (D) The board of directors of a special district that has an internet website and meets any of the following conditions:
(i) The boundaries of the special district include the entirety of a county with a population of 600,000 or more, and the special district has over 200 full-time equivalent employees. (ii) The special district has over 1,000 full-time equivalent employees. (iii) The special district has annual revenues, based on the most recent Financial Transaction Report data published by the California State Controller, that exceed four hundred million dollars ($400,000,000), adjusted annually for inflation commencing January 1, 2027, as measured by the percentage change in the California Consumer Price Index from January 1 of the prior year to January 1 of the current year, and the special district employs over 200 full-time equivalent employees. (3) “Two-way audiovisual platform” means an online platform that provides participants with the ability to participate in a meeting via both an interactive video conference and a two-way telephonic service. (4) “Two-way telephonic service” means a telephone service that does not require internet access and allows participants to dial a telephone number to listen and verbally participate. (f) This section shall become operative on July 1, 2026. (g) This section shall remain in effect only until January 1, 2030, and as of that date is repealed.
SEC. 6. Section 54953.5 of the Government Code is amended to read:
54953.5. (a) Any person attending an open and public meeting of a legislative body of a local agency shall have the right to record the proceedings in the absence of a reasonable finding by the legislative body of the local agency that the recording cannot continue without noise, illumination, or obstruction of view that constitutes, or would constitute, a persistent disruption of the proceedings. (b) Any recording of an open and public meeting made for whatever purpose by or at the direction of the local agency shall be subject to inspection pursuant to the California Public Records Act (Division 10 (commencing with Section 7920.000) of Title 1), but, notwithstanding Section 34090, may be erased or destroyed 30 days after the recording. Any inspection of an audio or video recording shall be provided without charge on equipment made available by the local agency.
SEC. 7. Section 54953.7 of the Government Code is amended to read:
54953.7. Notwithstanding any other provision of law, legislative bodies of local agencies may impose requirements upon themselves which allow greater access to their meetings than prescribed by the minimal standards set forth in this chapter. In addition thereto, an elected legislative body of a local agency may impose those requirements on appointed legislative bodies of the local agency.
SEC. 8. Section 54953.8 is added to the Government Code, to read:
54953.8. (a) The legislative body of a local agency may use teleconferencing as authorized by subdivision (b) of Section 54953 without complying with the requirements of paragraph (3) of subdivision (b) of Section 54953 in any of the circumstances described in Sections 54953.8.1 to 54953.8.7, inclusive. 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 11/25 Packet Pg. 490 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (b) A legislative body that holds a teleconference meeting pursuant to this section shall, in addition to any other applicable requirements of this chapter, comply with all of the following:
(1) The legislative body shall provide at least one of the following as a means by which the public may remotely hear and visually observe the meeting, and remotely address the legislative body:
(A) A two-way audiovisual platform.
(B) A two-way telephonic service and a live webcasting of the meeting. (2) In each instance in which notice of the time of the teleconference meeting held pursuant to this section is otherwise given or the agenda for the meeting is otherwise posted, the legislative body shall also give notice of the means by which members of the public may access the meeting and offer public comment. The agenda shall identify and include an opportunity for all persons to attend via a call-in option or an internet-based service option.
(3) In the event of a disruption that prevents the legislative body from broadcasting the meeting to members of the public using the call-in option or internet-based service option, or in the event of a disruption within the local agency’s control that prevents members of the public from offering public comments using the call-in option or internet-based service option, the legislative body shall take no further action on items appearing on the meeting agenda until public access to the meeting via the call-in option or internet-based service option is restored. Actions taken on agenda items during a disruption that prevents the legislative body from broadcasting the meeting may be challenged pursuant to Section 54960.1. (4) The legislative body shall not require public comments to be submitted in advance of the meeting and must provide an opportunity for the public to address the legislative body and offer comment in real time. (5) Notwithstanding Section 54953.3, an individual desiring to provide public comment through the use of an internet website, or other online platform, not under the control of the local legislative body, that requires registration to log in to a teleconference may be required to register as required by the third-party internet website or online platform to participate.
(6) (A) A legislative body that provides a timed public comment period for each agenda item shall not close the public comment period for the agenda item, or the opportunity to register, pursuant to paragraph (5), to provide public comment until that timed public comment period has elapsed. (B) A legislative body that does not provide a timed public comment period, but takes public comment separately on each agenda item, shall allow a reasonable amount of time per agenda item to allow public members the opportunity to provide public comment, including time for members of the public to register pursuant to paragraph (5), or otherwise be recognized for the purpose of providing public comment. (C) A legislative body that provides a timed general public comment period that does not correspond to a specific agenda item shall not close the public comment period or the opportunity to register, pursuant to paragraph (5), until the timed general public comment period has elapsed. (7) Any member of the legislative body who participates in a teleconference meeting from a remote location pursuant to this section and the specific provision of law that the member relied upon to permit their participation by teleconferencing shall be listed in the minutes of the meeting. (8) The legislative body shall have and implement a procedure for receiving and swiftly resolving requests for reasonable accommodation for individuals with disabilities, consistent with the federal Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12132), and resolving any doubt in favor of accessibility. In each instance in which notice of the time of the meeting is otherwise given or the agenda for the meeting is otherwise posted, the legislative body shall also give notice of the procedure for receiving and resolving requests for accommodation.
(9) The legislative body shall conduct meetings subject to this chapter consistent with applicable civil rights and nondiscrimination laws.
(c) A local agency shall identify and make available to legislative bodies a list of one or more meeting locations that may be available for use by the legislative bodies to conduct their meetings. (d) (1) Nothing in this section shall prohibit a legislative body from providing the public with additional teleconference locations.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 12/25 Packet Pg. 491 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (2) Nothing in this section shall prohibit a legislative body from providing the public with additional physical locations in which the public may observe and address the legislative body by electronic means. (e) A member of a legislative body who participates in a teleconference meeting from a remote location pursuant to this section shall publicly disclose at the meeting before any action is taken whether any other individuals 18 years of age or older are present in the room at the remote location with the member, and the general nature of the member’s relationship with those individuals.
(f) The teleconferencing provisions described in Section 54953 and Sections 54953.8.1 to 54953.8.7, inclusive, are cumulative. A legislative body may elect to use any teleconferencing provisions that are applicable to a meeting, regardless of whether any other teleconferencing provisions would also be applicable to that meeting. (g) For purposes of this section, the following definitions apply:
(1) “Remote location” means a location from which a member of a legislative body participates in a meeting pursuant to paragraph (7) of subdivision (b), other than any physical meeting location designated in the notice of the meeting. Remote locations need not be accessible to the public. (2) “Teleconference” means a meeting of a legislative body, the members of which are in different locations, connected by electronic means, through either audio or video, or both. (3) “Two-way audiovisual platform” means an online platform that provides participants with the ability to participate in a meeting via both an interactive video conference and a two-way telephonic service. A two-way audiovisual platform may be structured to disable the use of video for the public participants. (4) “Two-way telephonic service” means a telephone service that does not require internet access and allows participants to dial a telephone number to listen and verbally participate. (5) “Webcasting” means a streaming video broadcast online or on television, using streaming media technology to distribute a single content source to many simultaneous listeners and viewers.
SEC. 9. Section 54953.8.1 is added to the Government Code, to read:
54953.8.1. (a) A health authority may conduct a teleconference meeting pursuant to Section 54953.8, provided that it complies with the requirements of that section. (b) Nothing in this section or Section 54953.8 shall be construed as discouraging health authority members from regularly meeting at a common physical site within the jurisdiction of the authority or from using teleconference locations within or near the jurisdiction of the authority. (c) For purposes of this section, a health authority means any entity created pursuant to Sections 14018.7, 14087.31, 14087.35, 14087.36, 14087.38, and 14087.9605 of the Welfare and Institutions Code, any joint powers authority created pursuant to Article 1 (commencing with Section 6500) of Chapter 5 of Division 7 for the purpose of contracting pursuant to Section 14087.3 of the Welfare and Institutions Code, and any advisory committee to a county-sponsored health plan licensed pursuant to Chapter 2.2 (commencing with Section 1340) of Division 2 of the Health and Safety Code if the advisory committee has 12 or more members.
SEC. 10. Section 54953.8.2 is added to the Government Code, to read:
54953.8.2. (a) A legislative body of a local agency may conduct a teleconference meeting pursuant to Section 54953.8 during a proclaimed state of emergency or local emergency, provided that it complies with the requirements of that section and the teleconferencing is used in either of the following circumstances:
(1) For the purpose of determining, by majority vote, whether as a result of the emergency, meeting in person would present imminent risks to the health or safety of attendees. (2) After a determination described in paragraph (1) is made that, as a result of the emergency, meeting in person would present imminent risks to the health or safety of attendees. (b) If the state of emergency or local emergency remains active, in order to continue to teleconference pursuant to this section, the legislative body shall, no later than 45 days after teleconferencing for the first time pursuant to this section, and every 45 days thereafter, make the following findings by majority vote:
(1) The legislative body has reconsidered the circumstances of the state of emergency or local emergency. 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 13/25 Packet Pg. 492 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (2) The state of emergency or local emergency continues to directly impact the ability of the members to meet safely in person.
(c) This section shall not be construed to require the legislative body to provide a physical location from which the public may attend or comment.
(d) Notwithstanding paragraph (1) of subdivision (b) of Section 54953.8, a legislative body conducting a teleconference meeting pursuant to this section may elect to use a two-way telephonic service without a live webcasting of the meeting.
(e) For purposes of this section, the following definitions apply:
(1) “Local emergency” means a condition of extreme peril to persons or property proclaimed by the governing body of the local agency affected, in accordance with Section 8630 of the California Emergency Services Act (Chapter 7 (commencing with Section 8550) of Division 1 of Title 2), as defined in Section 8680.9, or a local health emergency declared pursuant to Section 101080 of the Health and Safety Code. Local emergency, as used in this section, refers only to local emergencies in the boundaries of the territory over which the local agency exercises jurisdiction.
(2) “State of emergency” means state of emergency proclaimed pursuant to Section 8625 of the California Emergency Services Act (Chapter 7 (commencing with Section 8550) of Division 1 of Title 2).
SEC. 11. Section 54953.8.3 is added to the Government Code, to read:
54953.8.3. (a) A legislative body of a local agency may conduct a teleconference meeting pursuant to Section 54953.8 if, during the teleconference meeting, at least a quorum of the members of the legislative body participates in person from a singular physical location clearly identified on the agenda, which location shall be open to the public and situated within the boundaries of the territory over which the local agency exercises jurisdiction, provided that the legislative body complies with the requirements of Section 54953.8 and all of the following additional requirements:
(1) A member of the legislative body notifies the legislative body at the earliest opportunity possible, including at the start of a regular meeting, of their need to participate remotely for just cause, including a general description of the circumstances relating to their need to appear remotely at the given meeting. (2) The member shall participate through both audio and visual technology. (3) (A) The provisions of this subdivision shall not serve as a means for any member of a legislative body to participate in meetings of the legislative body solely by teleconference from a remote location for just cause for more than the following number of meetings, as applicable:
(i) Two meetings per year, if the legislative body regularly meets once per month or less. (ii) Five meetings per year, if the legislative body regularly meets twice per month. (iii) Seven meetings per year, if the legislative body regularly meets three or more times per month. (B) For the purpose of counting meetings attended by teleconference under this paragraph, a “meeting” shall be defined as any number of meetings of the legislative body of a local agency that begin on the same calendar day.
(b) The minutes for the meeting shall identify the specific provision in subdivision (c) that each member relied upon to participate remotely. This subdivision shall not be construed to require the member to disclose any medical diagnosis or disability, or any personal medical information that is otherwise exempt under existing law, including, but not limited to, the Confidentiality of Medical Information Act (Chapter 1 (commencing with Section 56) of Part 2.6 of Division 1 of the Civil Code).
(c) For purposes of this section, “just cause” means any of the following:
(1) Childcare or caregiving need of a child, parent, grandparent, grandchild, sibling, spouse, or domestic partner that requires them to participate remotely. “Child,” “parent,” “grandparent,” “grandchild,” and “sibling” have the same meaning as those terms do in Section 12945.2. (2) A contagious illness that prevents a member from attending in person. 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 14/25 Packet Pg. 493 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (3) A need related to a physical or mental condition that is not subject to subdivision (c) of Section 54953. (4) Travel while on official business of the legislative body or another state or local agency. (5) An immunocompromised child, parent, grandparent, grandchild, sibling, spouse, or domestic partner of the member that requires the member to participate remotely. (6) A physical or family medical emergency that prevents a member from attending in person. (7) Military service obligations that result in a member being unable to attend in person because they are serving under official written orders for active duty, drill, annual training, or any other duty required as a member of the California National Guard or a United States Military Reserve organization that requires the member to be at least 50 miles outside the boundaries of the local agency. (d) This section shall remain in effect only until January 1, 2030, and as of that date is repealed.
SEC. 12. Section 54953.8.4 is added to the Government Code, to read:
54953.8.4. (a) An eligible neighborhood council may conduct a teleconference meeting pursuant to Section 54953.8, provided that it complies with the requirements of that section and all of the following have occurred:
(1) (A) The city council for a city described in paragraph (2) of subdivision (b) considers whether to adopt a resolution to authorize eligible neighborhood councils to use teleconferencing as described in this section at an open and regular meeting.
(B) If the city council adopts a resolution described in subparagraph (A), an eligible neighborhood council may elect to use teleconferencing pursuant to this section if a majority of the eligible neighborhood council votes to do so. The eligible neighborhood council shall notify the city council if it elects to use teleconferencing pursuant to this section and its justification for doing so. (C) Upon receiving notification from an eligible neighborhood council described in subparagraph (B), the city council may adopt a resolution to prohibit the eligible neighborhood council from using teleconferencing pursuant to this section.
(2) After completing the requirements of subparagraph (A) of paragraph (1), an eligible neighborhood council that holds a meeting pursuant to this subdivision shall do all of the following:
(A) At least a quorum of the members of the eligible neighborhood council shall participate from locations within the boundaries of the city in which the eligible neighborhood council is established. (B) At least once per year, at least a quorum of the members of the eligible neighborhood council shall participate in person from a singular physical location that is open to the public and within the boundaries of the eligible neighborhood council.
(3) If the meeting is during regular business hours of the offices of the city council member that represents the area that includes the eligible neighborhood council, the eligible neighborhood council shall provide a publicly accessible physical location from which the public may attend or comment, which shall be the offices of the city council member who represents the area where the eligible neighborhood council is located, unless the eligible neighborhood council identifies an alternative location. (4) If the meeting is outside regular business hours, the eligible neighborhood council shall make reasonable efforts to accommodate any member of the public that requests an accommodation to participate in the meeting.
(b) For purposes of this section, the following definitions apply:
(1) “Accommodation” means providing a publicly accessible physical location for the member of the public to participate from, providing access to technology necessary to participate in the meeting, or identifying locations or resources available that could provide the member of the public with an opportunity to participate in the meeting.
(2) “Eligible neighborhood council” means a neighborhood council that is an advisory body with the purpose to promote more citizen participation in government and make government more responsive to local needs that is established pursuant to the charter of a city with a population of more than 3,000,000 people that is subject to this chapter.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 15/25 Packet Pg. 494 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (c) This section shall remain in effect only until January 1, 2030, and as of that date is repealed.
SEC. 13. Section 54953.8.5 is added to the Government Code, to read:
54953.8.5. (a) An eligible community college student organization may conduct a teleconference meeting pursuant to Section 54953.8, provided that it complies with the requirements of that section and all of the following additional requirements:
(1) An eligible community college student organization may only use teleconferencing as described in Section 54953.8 after all the following have occurred:
(A) The board of trustees for a community college district considers whether to adopt a resolution to authorize eligible community college student organizations to use teleconferencing as described in this section at an open and regular meeting.
(B) If the board of trustees for a community college district adopts a resolution described in subparagraph (A), an eligible community college student organization may elect to use teleconferencing pursuant to this section if a majority of the eligible community college student organization votes to do so. The eligible community college student organization shall notify the board of trustees if it elects to use teleconferencing pursuant to this section and its justification for doing so. (C) Upon receiving notification from an eligible community college student organization as described in subparagraph (B), the board of trustees may adopt a resolution to prohibit the eligible community college student organization from using teleconferencing pursuant to this section. (D) (i) Except as specified in clause (ii), at least a quorum of the members of the eligible community college student organization shall participate from a singular physical location that is accessible to the public and is within the community college district in which the eligible community college student organization is established.
(ii) The requirements described in clause (i) shall not apply to the California Online Community College. (iii) Notwithstanding the requirements of clause (i), a person may count toward the establishment of a quorum pursuant to clause (i) regardless of whether the person is participating at the in-person location of the meeting or remotely if the person meets any of the following criteria:
(I) The person is under 18 years of age.
(II) The person is incarcerated.
(III) The person is unable to disclose the location that they are participating from because of either of the following circumstances:
(ia) The person has been issued a protective court order, including, but not limited to, a domestic violence restraining order.
(ib) The person is participating in a program that has to remain confidential, including, but not limited to, an independent living program.
(IV) The person provides childcare or caregiving to a child, parent, grandparent, grandchild, sibling, spouse, or domestic partner that requires them to participate remotely. For purposes of this subclause, “child,” “parent,” “grandparent,” “grandchild,” and “sibling” have the same meaning as those terms are defined in Section 12945.2.
(2) An eligible community college student organization that holds a meeting by teleconference as described in Section 54953.8 shall do the following, as applicable:
(A) (i) Except as specified in subparagraph (B), if the meeting is during regular business hours of the offices of the board of trustees of the community college district, the eligible community college student organization shall provide a publicly accessible physical location from which the public may attend or comment, which shall be the offices of the board of trustees of the community college district, unless the eligible community college student organization identifies an alternative location. (ii) Except as specified in subparagraph (B), if the meeting is outside regular business hours, the eligible community college student organization shall make reasonable efforts to accommodate any member of 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 16/25 Packet Pg. 495 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding the public that requests an accommodation to participate in the meeting. For the purposes of this subparagraph, “accommodation” means providing a publicly accessible physical location for the member of the public to participate from, providing access to technology necessary to participate in the meeting, or identifying locations or resources available that could provide the member of the public with an opportunity to participate in the meeting.
(B) The requirements described in subparagraph (A) shall not apply to the California Online Community College.
(b) For purposes of this section, “eligible community college student organization” means a student body association organized pursuant to Section 76060 of the Education Code, or any other student-run community college organization that is required to comply with the meeting requirements of this chapter, that is in any community college recognized within the California Community Colleges system and includes the Student Senate for California Community Colleges.
(c) This section shall remain in effect only until January 1, 2030, and as of that date is repealed.
SEC. 14. Section 54953.8.6 is added to the Government Code, to read:
54953.8.6. (a) An eligible subsidiary body may conduct a teleconference meeting pursuant to Section 54953.8, provided that it complies with the requirements of that section and all of the following additional requirements:
(1) The eligible subsidiary body shall designate one physical meeting location within the boundaries of the legislative body that created the eligible subsidiary body where members of the subsidiary body who are not participating remotely shall be present and members of the public may physically attend, observe, hear, and participate in the meeting. At least one staff member of the eligible subsidiary body or the legislative body that created the eligible subsidiary body shall be present at the physical meeting location during the meeting. The eligible subsidiary body shall post the agenda at the physical meeting location, but need not post the agenda at a remote location.
(2) (A) A member of the eligible subsidiary body shall visibly appear on camera during the open portion of a meeting that is publicly accessible via the internet or other online platform, except if the member has a physical or mental condition not subject to subdivision (c) of Section 54953 that results in a need to participate off camera.
(B) The visual appearance of a member of the eligible subsidiary body on camera may cease only when the appearance would be technologically infeasible, including, but not limited to, when the member experiences a lack of reliable broadband or internet connectivity that would be remedied by joining without video. (C) If a member of the eligible subsidiary body does not appear on camera due to challenges with internet connectivity, the member shall announce the reason for their nonappearance prior to turning off their camera.
(3) An elected official serving as a member of an eligible subsidiary body in their official capacity shall not participate in a meeting of the eligible subsidiary body by teleconferencing pursuant to this section unless the use of teleconferencing complies with the requirements of paragraph (3) of subdivision (b) of Section 54953. (4) (A) In order to use teleconferencing pursuant to this section, the legislative body that established the eligible subsidiary body by charter, ordinance, resolution, or other formal action shall make the following findings by majority vote before the eligible subsidiary body uses teleconferencing pursuant to this section for the first time, and every six months thereafter:
(i) The legislative body has considered the circumstances of the eligible subsidiary body. (ii) Teleconference meetings of the eligible subsidiary body would enhance public access to meetings of the eligible subsidiary body, and the public has been made aware of the type of remote participation, including audio-visual or telephonic, that will be made available at a regularly scheduled meeting and has been provided the opportunity to comment at an in-person meeting of the legislative body authorizing the subsidiary body to meet entirely remotely.
(iii) Teleconference meetings of the eligible subsidiary body would promote the attraction, retention, and diversity of eligible subsidiary body members.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 17/25 Packet Pg. 496 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (B) (i) An eligible subsidiary body authorized to use teleconferencing pursuant to this section may request to present any recommendations it develops to the legislative body that created it. (ii) Upon receiving a request described in clause (i), the legislative body that created the subsidiary body shall hold a discussion at a regular meeting held within 60 days after the legislative body receives the request, or if the legislative body does not have another regular meeting scheduled within 60 days after the legislative body receives the request, at the next regular meeting after the request is received. (iii) The discussion required by clause (ii) shall not be placed on a consent calendar, but may be combined with the legislative body’s subsequent consideration of the findings described in subparagraph (A) for the following 12 months.
(iv) The legislative body shall not take any action on any recommendations included in the report of a subsidiary body until the next regular meeting of the legislative body following the discussion described in clause (ii).
(C) After the legislative body makes the findings described in subparagraph (A), the eligible subsidiary body shall approve the use of teleconferencing by majority vote before using teleconference pursuant to this section.
(D) The legislative body that created the eligible subsidiary body may elect to prohibit the eligible subsidiary body from using teleconferencing pursuant to this section at any time. (b) (1) For purposes of this section, “eligible subsidiary body” means a legislative body that meets all of the following:
(A) Is described in subdivision (b) of Section 54952.
(B) Serves exclusively in an advisory capacity.
(C) Is not authorized to take final action on legislation, regulations, contracts, licenses, permits, or any other entitlements, grants, or allocations of funds.
(D) Does not have primary subject matter jurisdiction, as defined by the charter, an ordinance, a resolution, or any formal action of the legislative body that created the subsidiary body, that focuses on elections, budgets, police oversight, privacy, removing from, or restricting access to, materials available in public libraries, or taxes or related spending proposals.
(2) An eligible subsidiary body may include members who are elected officials, members who are not elected officials, or any combination thereof.
(c) This section shall remain in effect only until January 1, 2030, and as of that date is repealed.
SEC. 15. Section 54953.8.7 is added to the Government Code, to read:
54953.8.7. (a) An eligible multijurisdictional body may conduct a teleconference meeting pursuant to Section 54953.8, provided that it complies with the requirements of that section and all of the following additional requirements:
(1) The eligible multijurisdictional body has adopted a resolution that authorizes the eligible multijurisdictional body to use teleconferencing pursuant to this section at a regular meeting in open session. (2) At least a quorum of the members of the eligible multijurisdictional body shall participate from one or more physical locations that are open to the public and within the boundaries of the territory over which the local agency exercises jurisdiction.
(3) A member of the eligible multijurisdictional body who receives compensation for their service on the eligible multijurisdictional body shall participate from a physical location that is open to the public. For purposes of this paragraph, “compensation” does not include reimbursement for actual and necessary expenses.
(4) A member of the eligible multijurisdictional body may participate from a remote location provided that:
(A) The eligible multijurisdictional body identifies each member of the eligible multijurisdictional body who plans to participate remotely in the agenda.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 18/25 Packet Pg. 497 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (B) The member shall participate through both audio and visual technology. (5) A member of the eligible multijurisdictional body shall not participate in a meeting remotely pursuant to this section, unless the location from which the member participates is more than 20 miles each way from any physical location of the meeting described in paragraph (2). (6) The provisions of this section shall not serve as a means for any member of a legislative body to participate in meetings of the legislative body solely by teleconference from a remote location for more than the following number of meetings, as applicable:
(A) Two meetings per year, if the legislative body regularly meets once per month or less. (B) Five meetings per year, if the legislative body regularly meets twice per month. (C) Seven meetings per year, if the legislative body regularly meets three or more times per month. (D) For the purpose of counting meetings attended by teleconference under this paragraph, a “meeting” shall be defined as any number of meetings of the legislative body of a local agency that begin on the same calendar day.
(b) For the purposes of this section, both of the following definitions apply:
(1) “Eligible multijurisdictional body” means a multijurisdictional board, commission, or advisory body of a multijurisdictional, cross-county agency, the membership of which board, commission, or advisory body is appointed, and the board, commission, or advisory body is otherwise subject to this chapter. (2) “Multijurisdictional” means either of the following:
(A) A legislative body that includes representatives from more than one county, city, city and county, or special district.
(B) A legislative body of a joint powers entity formed pursuant to an agreement entered into in accordance with Article 1 (commencing with Section 6500) of Chapter 5 of Division 7 of Title 1. (c) This section shall remain in effect only until January 1, 2030, and as of that date is repealed.
SEC. 16. Section 54954.2 of the Government Code, as amended by Section 92 of Chapter 131 of the Statutes of 2023, is amended to read:
54954.2. (a) (1) At least 72 hours before a regular meeting, the legislative body of the local agency, or its designee, shall post an agenda that meets all of the following requirements:
(A) The agenda shall contain a brief general description of each item of business to be transacted or discussed at the meeting, including items to be discussed in closed session. A brief general description of an item generally need not exceed 20 words.
(B) The agenda shall specify the time and location of the regular meeting and shall be posted in a location that is freely accessible to members of the public and on the local agency’s internet website, if the local agency has one.
(C) (i) If requested, the agenda shall be made available in appropriate alternative formats to persons with a disability, as required by Section 202 of the Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12132), and the federal rules and regulations adopted in implementation thereof. (ii) The agenda shall include information regarding how, to whom, and when a request for disabilityrelated modification or accommodation, including auxiliary aids or services, may be made by a person with a disability who requires a modification or accommodation in order to participate in the public meeting.
(2) For a meeting occurring on and after January 1, 2019, of a legislative body of a city, county, city and county, special district, school district, or political subdivision established by the state that has an internet website, the following provisions shall apply:
(A) An online posting of an agenda shall be posted on the primary internet website home page of a city, county, city and county, special district, school district, or political subdivision established by the state that 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 19/25 Packet Pg. 498 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding is accessible through a prominent, direct link to the current agenda. The direct link to the agenda shall not be in a contextual menu; however, a link in addition to the direct link to the agenda may be accessible through a contextual menu.
(B) An online posting of an agenda, including, but not limited to, an agenda posted in an integrated agenda management platform, shall be posted in an open format that meets all of the following requirements:
(i) Retrievable, downloadable, indexable, and electronically searchable by commonly used internet search applications.
(ii) Platform independent and machine readable.
(iii) Available to the public free of charge and without any restriction that would impede the reuse or redistribution of the agenda.
(C) A legislative body of a city, county, city and county, special district, school district, or political subdivision established by the state that has an internet website and an integrated agenda management platform shall not be required to comply with subparagraph (A) if all of the following are met:
(i) A direct link to the integrated agenda management platform shall be posted on the primary internet website home page of a city, county, city and county, special district, school district, or political subdivision established by the state. The direct link to the integrated agenda management platform shall not be in a contextual menu. When a person clicks on the direct link to the integrated agenda management platform, the direct link shall take the person directly to an internet website with the agendas of the legislative body of a city, county, city and county, special district, school district, or political subdivision established by the state.
(ii) The integrated agenda management platform may contain the prior agendas of a legislative body of a city, county, city and county, special district, school district, or political subdivision established by the state for all meetings occurring on or after January 1, 2019. (iii) The current agenda of the legislative body of a city, county, city and county, special district, school district, or political subdivision established by the state shall be the first agenda available at the top of the integrated agenda management platform.
(iv) All agendas posted in the integrated agenda management platform shall comply with the requirements in clauses (i), (ii), and (iii) of subparagraph (B). (D) The provisions of this paragraph shall not apply to a political subdivision of a local agency that was established by the legislative body of the city, county, city and county, special district, school district, or political subdivision established by the state.
(E) For purposes of this paragraph, both of the following definitions apply:
(1) “Integrated agenda management platform” means an internet website of a city, county, city and county, special district, school district, or political subdivision established by the state dedicated to providing the entirety of the agenda information for the legislative body of the city, county, city and county, special district, school district, or political subdivision established by the state to the public. (2) “Legislative body” means a legislative body that meets the definition of subdivision (a) of Section 54952. (3) No action or discussion shall be undertaken on any item not appearing on the posted agenda, except that members of a legislative body or its staff may briefly respond to statements made or questions posed by persons exercising their public testimony rights under Section 54954.3. In addition, on their own initiative or in response to questions posed by the public, a member of a legislative body or its staff may ask a question for clarification, make a brief announcement, or make a brief report on their own activities. Furthermore, a member of a legislative body, or the body itself, subject to rules or procedures of the legislative body, may provide a reference to staff or other resources for factual information, request staff to report back to the body at a subsequent meeting concerning any matter, or take action to direct staff to place a matter of business on a future agenda.
(b) Notwithstanding subdivision (a), the legislative body may take action on items of business not appearing on the posted agenda under any of the conditions stated below. Prior to discussing any item pursuant to this subdivision, the legislative body shall publicly identify the item. 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 20/25 Packet Pg. 499 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (1) Upon a determination by a majority vote of the legislative body that an emergency situation exists, as defined in Section 54956.5.
(2) Upon a determination by a two-thirds vote of the members of the legislative body present at the meeting, or, if less than two-thirds of the members are present, a unanimous vote of those members present, that there is a need to take immediate action and that the need for action came to the attention of the local agency subsequent to the agenda being posted as specified in subdivision (a). (3) The item was posted pursuant to subdivision (a) for a prior meeting of the legislative body occurring not more than five calendar days prior to the date action is taken on the item, and at the prior meeting the item was continued to the meeting at which action is being taken. (c) This section is necessary to implement and reasonably within the scope of paragraph (1) of subdivision (b) of Section 3 of Article I of the California Constitution.
(d) For purposes of subdivision (a), the requirement that the agenda be posted on the local agency’s internet website, if the local agency has one, shall only apply to a legislative body that meets either of the following standards:
(1) A legislative body as that term is defined by subdivision (a) of Section 54952. (2) A legislative body as that term is defined by subdivision (b) of Section 54952, if the members of the legislative body are compensated for their appearance, and if one or more of the members of the legislative body are also members of a legislative body as that term is defined by subdivision (a) of Section 54952.
SEC. 17. Section 54954.3 of the Government Code is amended to read:
54954.3. (a) (1) Every agenda for regular meetings shall provide an opportunity for members of the public to directly address the legislative body on any item of interest to the public, before or during the legislative body’s consideration of the item, that is within the subject matter jurisdiction of the legislative body, provided that no action shall be taken on any item not appearing on the agenda unless the action is otherwise authorized by subdivision (b) of Section 54954.2.
(2) (A) Notwithstanding paragraph (1), the agenda need not provide an opportunity for members of the public to address the legislative body on any item that has already been considered by a committee, composed exclusively of members of the legislative body, at a public meeting wherein all interested members of the public were afforded the opportunity to address the committee on the item, before or during the committee’s consideration of the item.
(B) Subparagraph (A) shall not apply if any of the following conditions are met:
(i) The item has been substantially changed since the committee heard the item, as determined by the legislative body.
(ii) When considering the item, a quorum of the committee members did not participate from a singular physical location, that was clearly identified on the agenda, open to the public, and situated within the boundaries of the territory over which the local agency exercises jurisdiction. (iii) The committee has primary subject matter jurisdiction, as defined by the charter, an ordinance, a resolution, or any formal action of the legislative body that created the subsidiary body, that focuses on elections, budgets, police oversight, privacy, removing from, or restricting access to, materials available in public libraries, or taxes or related spending proposals. This clause shall not apply to an item if the local agency has adopted a law applicable to the meeting of the committee at which the item that was considered prohibits the committee from placing a limit on the total amount of time for public comment on the item.
(3) Every notice for a special meeting shall provide an opportunity for members of the public to directly address the legislative body concerning any item that has been described in the notice for the meeting before or during consideration of that item.
(b) (1) The legislative body of a local agency may adopt reasonable regulations to ensure that the intent of subdivision (a) is carried out, including, but not limited to, regulations limiting the total amount of time allocated for public testimony on particular issues and for each individual speaker. 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 21/25 Packet Pg. 500 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (2) Notwithstanding paragraph (1), when the legislative body of a local agency limits time for public comment, the legislative body of a local agency shall provide at least twice the allotted time to a member of the public who utilizes a translator to ensure that non-English speakers receive the same opportunity to directly address the legislative body of a local agency.
(3) Paragraph (2) shall not apply if the legislative body of a local agency utilizes simultaneous translation equipment in a manner that allows the legislative body of a local agency to hear the translated public testimony simultaneously.
(c) The legislative body of a local agency shall not prohibit public criticism of the policies, procedures, programs, or services of the agency, or of the acts or omissions of the legislative body. Nothing in this subdivision shall confer any privilege or protection for expression beyond that otherwise provided by law.
SEC. 18. Section 54956 of the Government Code is amended to read:
54956. (a) (1) A special meeting may be called at any time by the presiding officer of the legislative body of a local agency, or by a majority of the members of the legislative body, by delivering written notice to each member of the legislative body and to each local newspaper of general circulation and radio or television station requesting notice in writing and posting a notice on the local agency’s internet website, if the local agency has one. The notice shall be delivered personally or by any other means and shall be received at least 24 hours before the time of the meeting as specified in the notice. The call and notice shall specify the time and place of the special meeting and the business to be transacted or discussed. No other business shall be considered at these meetings by the legislative body. The written notice may be dispensed with as to any member who at or prior to the time the meeting convenes files with the clerk or secretary of the legislative body a written waiver of notice. The waiver may be given by telephone or electronic mail. The written notice may also be dispensed with as to any member who is actually present at the meeting at the time it convenes. (2) The call and notice shall be posted at least 24 hours prior to the special meeting in a location that is freely accessible to members of the public.
(b) Notwithstanding any other law, a legislative body shall not call a special meeting regarding the salaries, salary schedules, or compensation paid in the form of fringe benefits, of the legislative body or of a local agency executive, as defined in subdivision (d) of Section 3511.1. However, this subdivision does not apply to a local agency calling a special meeting to discuss the local agency’s budget.
SEC. 19. Section 54956.5 of the Government Code is amended to read:
54956.5. (a) For purposes of this section, “emergency situation” means both of the following:
(1) An emergency, which shall be defined as a work stoppage, crippling activity, or other activity that severely impairs public health, safety, or both, as determined by a majority of the members of the legislative body. (2) A dire emergency, which shall be defined as a crippling disaster, mass destruction, terrorist act, or threatened terrorist activity that poses peril so immediate and significant that requiring a legislative body to provide one-hour notice before holding an emergency meeting under this section may endanger the public health, safety, or both, as determined by a majority of the members of the legislative body. (b) (1) Subject to paragraph (2), in the case of an emergency situation involving matters upon which prompt action is necessary due to the disruption or threatened disruption of public facilities, a legislative body may hold an emergency meeting without complying with either the 24-hour notice requirement or the 24-hour posting requirement of Section 54956 or both of the notice and posting requirements. (2) Each local newspaper of general circulation and radio or television station that has requested notice of special meetings pursuant to Section 54956 shall be notified by the presiding officer of the legislative body, or designee thereof, one hour prior to the emergency meeting, or, in the case of a dire emergency, at or near the time that the presiding officer or designee notifies the members of the legislative body of the emergency meeting.
(A) Except as provided in subparagraph (B), the notice required by this paragraph shall be given by telephone and all telephone numbers provided in the most recent request of a newspaper or station for notification of special meetings shall be exhausted. In the event that telephone services are not functioning, the notice requirements of this paragraph shall be deemed waived, and the legislative body, or designee of 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 22/25 Packet Pg. 501 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding the legislative body, shall notify those newspapers, radio stations, or television stations of the fact of the holding of the emergency meeting, the purpose of the meeting, and any action taken at the meeting as soon after the meeting as possible.
(B) For an emergency meeting held pursuant to this section, the presiding officer of the legislative body, or designee thereof, may send the notifications required by this paragraph by email instead of by telephone, as provided in subparagraph (A), to all local newspapers of general circulation, and radio or television stations, that have requested those notifications by email, and all email addresses provided by representatives of those newspapers or stations shall be exhausted. In the event that internet services and telephone services are not functioning, the notice requirements of this paragraph shall be deemed waived, and the legislative body, or designee of the legislative body, shall notify those newspapers, radio stations, or television stations of the fact of the holding of the emergency meeting, the purpose of the meeting, and any action taken at the meeting as soon after the meeting as possible.
(c) During a meeting held pursuant to this section, the legislative body may meet in closed session pursuant to Section 54957 if agreed to by a two-thirds vote of the members of the legislative body present, or, if less than two-thirds of the members are present, by a unanimous vote of the members present. (d) All special meeting requirements, as prescribed in Section 54956 shall be applicable to a meeting called pursuant to this section, with the exception of the 24-hour notice requirement. (e) The minutes of a meeting called pursuant to this section, a list of persons who the presiding officer of the legislative body, or designee of the legislative body, notified or attempted to notify, a copy of the rollcall vote, and any actions taken at the meeting shall be posted for a minimum of 10 days in a public place as soon after the meeting as possible.
SEC. 20. Section 54957.6 of the Government Code is amended to read:
54957.6. (a) Notwithstanding any other provision of law, a legislative body of a local agency may hold closed sessions with the local agency’s designated representatives regarding the salaries, salary schedules, or compensation paid in the form of fringe benefits of its represented and unrepresented employees, and, for represented employees, any other matter within the statutorily provided scope of representation, subject to all of the following conditions:
(1) Prior to the closed session, the legislative body of the local agency shall hold an open and public session in which it identifies its designated representatives.
(2) The closed session shall be for the purpose of reviewing its position and instructing the local agency’s designated representatives.
(3) The closed session may take place prior to and during consultations and discussions with representatives of employee organizations and unrepresented employees.
(4) Any closed session with the local agency’s designated representative regarding the salaries, salary schedules, or compensation paid in the form of fringe benefits may include discussion of an agency’s available funds and funding priorities, but only insofar as these discussions relate to providing instructions to the local agency’s designated representative.
(5) The closed session shall not include final action on the proposed compensation of one or more unrepresented employees.
(6) For the purposes enumerated in this section, a legislative body of a local agency may also meet with a state conciliator who has intervened in the proceedings. (b) For the purposes of this section, the term “employee” shall include an officer or an independent contractor who functions as an officer or an employee, but shall not include any elected official, member of a legislative body, or other independent contractors.
SEC. 21. Section 54957.9 of the Government Code is amended to read:
54957.9. In the event that any meeting is willfully interrupted by a group or groups of persons so as to render the orderly conduct of the meeting unfeasible and order cannot be restored by the removal of individuals who are willfully interrupting the meeting, the members of the legislative body conducting the meeting may order the 5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 23/25 Packet Pg. 502 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding meeting room cleared and continue in session. Only matters appearing on the agenda may be considered in such a session. Representatives of the press or other news media, except those participating in the disturbance, shall be allowed to attend any session held pursuant to this section. Nothing in this section shall prohibit the legislative body from establishing a procedure for readmitting an individual or individuals not responsible for willfully disturbing the orderly conduct of the meeting.
SEC. 22. Section 54957.95 of the Government Code is amended to read:
54957.95. (a) (1) In addition to authority exercised pursuant to Sections 54954.3 and 54957.9, the presiding member of the legislative body conducting a meeting or their designee may remove, or cause the removal of, an individual for disrupting the meeting, including any teleconferenced meeting. (2) Prior to removing an individual, the presiding member or their designee shall warn the individual that their behavior is disrupting the meeting and that their failure to cease their behavior may result in their removal.
The presiding member or their designee may then remove the individual if they do not promptly cease their disruptive behavior. This paragraph does not apply to any behavior described in subparagraph (B) of paragraph (1) of subdivision (b).
(b) As used in this section:
(1) “Disrupting” means engaging in behavior during a meeting of a legislative body that actually disrupts, disturbs, impedes, or renders infeasible the orderly conduct of the meeting and includes, but is not limited to, one of the following:
(A) A failure to comply with reasonable and lawful regulations adopted by a legislative body pursuant to Section 54954.3 or any other law.
(B) Engaging in behavior that constitutes use of force or a true threat of force. (2) “True threat of force” means a threat that has sufficient indicia of intent and seriousness, that a reasonable observer would perceive it to be an actual threat to use force by the person making the threat.
SEC. 23. Section 54957.96 is added to the Government Code, to read:
54957.96. (a) The existing authority of a legislative body or its presiding officer to remove or limit participation by persons who engage in behavior that actually disrupts, disturbs, impedes, or renders infeasible the orderly conduct of the meeting, including existing limitations upon that authority, shall apply to members of the public participating in a meeting via a two-way telephonic service or a two-way audiovisual platform. (b) For purposes of this section, the following definitions apply:
(1) “Two-way audiovisual platform” means an online platform that provides participants with the ability to participate in a meeting via both an interactive video conference and a two-way telephonic service. A two-way audiovisual platform may be structured to disable the use of video for the public participants. (2) “Two-way telephonic service” means a telephone service that does not require internet access and allows participants to dial a telephone number to listen and verbally participate.
SEC. 24. The Legislature finds and declares that Section 4 of this act, which amends Section 54953 of, Section 5 of this act, which adds Section 54953.4 to, Sections 8 to 15, inclusive, of this act, which add Sections 54953.8 to 54953.8.7, respectively, to, Section 19 of this act, which amends Section 54956.5 of, Section 22 of this act, which amends Section 54957.95 of, and Section 23 of this act, which adds Section 54957.96 to, the Government Code, impose a limitation on the public’s right of access to the meetings of public bodies or the writings of public officials and agencies within the meaning of Section 3 of Article I of the California Constitution. Pursuant to that constitutional provision, the Legislature makes the following findings to demonstrate the interest protected by this limitation and the need for protecting that interest:
(a) This act is necessary to provide opportunities for public participation in meetings of specified public agencies and to promote the recruitment and retention of members of those agencies. (b) This act is necessary to ensure minimum standards for public participation and notice requirements allowing for greater public participation in meetings.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 24/25 Packet Pg. 503 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding (c) This act is necessary to modernize the Ralph M. Brown Act to reflect recent technological changes that can promote greater public access to local officials.
(d) The exclusively virtual nature of the California Online Community College presents unique barriers to the requirements for an in-person quorum, a physical location for public participation, and certain accommodations.
Participating students of the online community college come from all across the state and necessitating travel for these requirements would pose a significant and exclusionary barrier.
SEC. 25. The Legislature finds and declares that Sections 1 and 2 of this act, which amend and repeal Section 54952.2, respectively, of, Section 3 of this act, which amends Section 54952.7 of, Section 4 of this act, which amends Section 54953 of, Section 5 of this act, which adds Section 54953.4 to, Section 6 of this act, which amends Section 54953.5 of, Section 7 of this act, which amends Section 54953.7 of, Sections 8 to 15, inclusive, of this act, which add Sections 54953.8 to 54953.8.7, respectively, to, Section 16 of this act, which amends Section 54954.2 of, Section 17 of this act, which amends Section 54954.3 of, Section 18 of this act, which amends Section 54956 of, Section 19 of this act, which amends Section 54956.5 of, Section 20 of this act, which amends Section 54957.6 of, Section 21 of this act, which amends Section 54957.9 of, Section 22 of this act, which amends Section 54957.95 of, and Section 23 of this act, which adds Section 54957.96 to, the Government Code, further, within the meaning of paragraph (7) of subdivision (b) of Section 3 of Article I of the California Constitution, the purposes of that constitutional section as it relates to the right of public access to the meetings of local public bodies or the writings of local public officials and local agencies. Pursuant to paragraph (7) of subdivision (b) of Section 3 of Article I of the California Constitution, the Legislature makes the following findings:
(a) This act is necessary to provide opportunities for public participation in meetings of specified public agencies and to promote the recruitment and retention of members of those agencies. (b) This act is necessary to ensure minimum standards for public participation and notice requirements allowing for greater public participation in meetings.
(c) This act is necessary to modernize the Ralph M. Brown Act to reflect recent technological changes that can promote greater public access to local officials.
(d) The exclusively virtual nature of the California Online Community College presents unique barriers to the requirements for an in-person quorum, a physical location for public participation, and certain accommodations.
Participating students of the online community college come from all across the state and necessitating travel for these requirements would pose a significant and exclusionary barrier.
SEC. 26. The Legislature finds and declares that adequate public access to meetings is a matter of statewide concern and is not a municipal affair as that term is used in Section 5 of Article XI of the California Constitution.
Therefore, this bill would apply to all cities, including charter cities.
SEC. 27. No reimbursement is required by this act pursuant to Section 6 of Article XIII B of the California Constitution because the only costs that may be incurred by a local agency or school district under this act would result from a legislative mandate that is within the scope of paragraph (7) of subdivision (b) of Section 3 of Article I of the California Constitution.
5/27/26, 4:45 PM Bill Text - SB-707 Open meetings: meeting and teleconference requirements. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB707 25/25 Packet Pg. 504 Attachment: Bill Text - SB-707 Open meetings_ meeting and teleconference requirements_ (9.12(c)--Report re: impacts of SB 707 regarding