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-HOUSE BILL 165
+Fiscal impact reports (FIRs) are prepared by the Legislative Finance Committee (LFC) for standing finance
+committees of the Legislature. LFC does not assume respon sibility for the accuracy of these reports if they
+are used for other purposes.
-57th legislature - STATE OF NEW MEXICO - second session, 2026
+F I S C A L I M P A C T R E P O R T
-INTRODUCED BY
+BILL NUMBER: House Bill 165
+SHORT TITLE: Payment Of Certain IRB Special Assessments
+SPONSOR: Serrato/Dixon
+LAST
+UPDATE:
+ORIGINAL
+DATE: 1/30/25
-Linda Serrato and Meredith A. Dixon and D. Wonda Johnson
+ANALYST: Torres
-and Cynthia Borrego
+REVENUE*
+(dollars in thousands)
+Type FY26 FY27 FY28 FY29 FY30 Recurring or
+Nonrecurring
+Fund
+Affected
+Property Tax
+Assessments No fiscal impact Nonrecurring Local
+Governments
+Parentheses indicate revenue decreases.
+*Amounts reflect most recent analysis of this legislation.
-AN ACT
+Sources of Information
-RELATING TO LOCAL GOVERNMENT; CLARIFYING THAT SPECIAL
-ASSESSMENTS UNDER THE IMPROVEMENT SPECIAL ASSESSMENT ACT SHALL
-BE PAID BY PROPERTY OWNERS OR LESSEES WHO HOLD INDUSTRIAL
-REVENUE BOND LEASES.
+LFC Files
-BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF NEW MEXICO:
+Agency or Agencies Providing Analysis
+New Mexico Attorney General
+Economic Development Department
+State Ethics Commission
-     SECTION 1. Section 4-55D-2 NMSA 1978 (being Laws 2023,
-Chapter 150, Section 2) is amended to read:
+SUMMARY
-     "4-55D-2. DEFINITIONS.--As used in the Improvement
-Special Assessment Act:
+Synopsis of House Bill 165
-          A. "capital provider" means a private entity or its
-designee, successor or assigns that finances or refinances an
-eligible improvement pursuant to the Improvement Special
-Assessment Act;
+House Bill 165 (HB165) amends the Improvement Special Assessment Act to clarify that special
+assessments imposed under the act must be paid by the property owner, or by the lessee when the
+property is subject to an industrial revenue bond (IRB) lease. The bill makes conforming changes
+to statutory definitions and enforcement provisions to ensure that lessees under IRB leases are
+explicitly responsible for payment of special assessments associated with eligible improvements.
-          B. "county" means a county, including an H class
-county;
+Specifically, the bill amends Section 4 -55D-2 NMSA 1978 to add property interests held by a
+lessee under eligible properties for special assessment improvements. The bill amends Section 4-
+55D-5 NMSA 1978 to explicitly state that a special assessment shall be paid by the lessee when
+property is under an IRB lease , and that under no circumstances shall a local government be
+responsible for payment of a special assessment. The bill also clarifies that counties and
+municipalities do not pledge their credit or assume liability for special assessment financing and
+reinforces existing immunity provisions.
+House Bill 165 – Page 2
-          C. "county ordinance" means an ordinance adopted by
-a county pursuant to the Improvement Special Assessment Act to
-establish a program within a designated region;
+This bill does not contain an effective date and, as a result, would go into effect 90 days after the
+Legislature adjourns, which is May 20, 2026.
+FISCAL IMPLICATIONS
-          D. "department" means the economic development
-department;
+House Bill 165 has no direct fiscal impact on the general fund or state revenues. The bill does
+not impose new taxes, create new credits or exemptions, or authorize state expenditures.
-          E. "eligible improvement" means a permanently
-affixed energy efficiency improvement, renewable energy
-improvement, water conservation improvement or resiliency
-improvement installed on eligible property as part of the
-construction or renovation of the property;
+At the local government level, the bill may have indirect fiscal implications by allowing
+properties under an IRB to access special assessment improvements. These assessments are used
+as a financing mechanism called Commercial Property Assessed Clean Energy (C -PACE)
+financing. C-PACE is a financing mechanism enabling owners of commercial, industrial, and
+multifamily properties to secure low -cost, long- term funding for energy efficiency, water
+conservation, and renewable energy upgrades. It provides up to 100 percent of project costs —
+often 20 percent to 35 percent of total development costs —repaid through a voluntary property
+tax assessment over 20 -30 years. As a local assessment, there may be some additional, but de
+minimis administrative costs for local governments to administer another transaction.
-          F. "eligible property" means:
+Since properties under an IRB do not have a property tax assessment, the bill clarifies that the
+voluntary payment can be made by the lessee for the purpose of the improvements and allows
+IRB properties to engage with the C-PACE funding mechanism.
-                (1) any privately owned commercial,
-industrial, agricultural or multifamily residential real
-property with five or more dwelling units, including real
-property owned by an entity formally recognized as tax exempt
-pursuant to Internal Revenue Code of 1986, as amended; or
+The strong protections included in the bill ensure IRB lessees—not counties or municipalities —
+are responsible for special assessments, and the bill reduces the risk that local governments could
+be exposed to payment obligations or collection shortfalls.
-                (2) property interests of a lessee under an
-industrial revenue bond lease for commercial, industrial,
-agricultural or multifamily residential real property with five
-or more dwelling units;
+By expanding the pool of eligible candidates for C -PACE funding, the bill may improve the
+credit quality and enforceability of special assessment liens on IRB -developed property,
+lowering financing costs for development of such properties . To the extent this facilitates
+additional private financing of energy, water conservation, or resiliency improvements, there
+could be secondary economic activity with associated gross receipts tax and employment impacts
+from increased development activity.
-          G. "energy efficiency improvement" means measures,
-equipment or devices that result in a decrease in consumption
-of or demand for electricity or natural gas;
+SIGNIFICANT ISSUES
-          H. "industrial revenue bond lease" means the lease
-of property by a county or municipality to a person in
-connection with a project under the authority of the Industrial
-Revenue Bond Act or the County Industrial Revenue Bond Act;
+HB165 addresses a structural ambiguity that arises when publicly owned property subject to an
+IRB lease would like to participate in a special assessment financing program. Under IRB
+arrangements, legal title is held by a county or municipality, while the private lessee enjoys
+beneficial use and economic control. Without statutory clarification, this structure prevents IRB
+lessees from accessing certain financing mechanisms. This bill would allow lessees to access
+special assessment improvement financing such as C -PACE financing, as described in the fiscal
+implications section above. The bill also ensures clarity that a local government could not be
+deemed responsible for assessment payments.
-          I. "lessee" means a lessee under an industrial
-revenue bond lease;
+By explicitly assigning responsibility to the lessee, the bill:
+• aligns payment obligations with the party receiving the economic benefit of the
+improvements;
+• reinforces the principle that IRBs should not expose local governments to financial
+House Bill 165 – Page 3
-          [H.] J. "local government" means a municipality,
-county or other general function governmental unit established
-by state law;
+liability beyond their intended role; and
+• reduces legal and financial risk to counties and municipalities participating in
+improvement special assessment programs.
-          [I.] K. "municipal" or "municipality" means any
-incorporated city, town or village, whether incorporated under
-general act, special act or special charter, incorporated
-counties and H class counties;
+The clarification may also increase participation by IRB lessees in special assessment programs
+by providing certainty to capital providers that assessments are enforceable against the
+appropriate obligor.
-          [J.] L. "program" means a special assessment
-program that utilizes and conforms to the program guidebook and
-uniform special assessment documents established by the
-department pursuant to the Improvement Special Assessment Act;
-
-          [K.] M. "program administrator" means a person
-designated by a county to administer a program; "program
-administrator" may be the department, the county or a third
-party; provided that the administration procedures used conform
-to the requirements of the Improvement Special Assessment Act;
-
-          [L.] N. "program guidebook" means a comprehensive
-document created by the department pursuant to the Improvement
-Special Assessment Act, including uniform assessment documents,
-appropriate guidelines, specifications, approval criteria and
-other standard forms consistent with the administration of a
-program that are not detailed in the Improvement Special
-Assessment Act;
-
-          [M.] O. "project application" means an application
-submitted to a program administrator to demonstrate that a
-proposed project qualifies for special assessment financing
-pursuant to a program;
-
-          [N.] P. "region" means a geographical area as
-designated by a county pursuant to the Improvement Special
-Assessment Act;
-
-          [O.] Q. "renewable energy improvement" means an
-energy system that generates energy by use of low- or zero-emissions generation technology with substantial long-term
-production, including solar, wind and geothermal resources,
-fuel cell equipment using an electrochemical process to
-generate electricity and heat or biomass resources;
-
-          [P.] R. "resiliency improvement" means improvements
-that increase the resilience of a property, including air
-quality, flood mitigation, storm water management, energy
-storage and microgrids, alternative vehicle charging
-infrastructure, fire or wind resistance or inundation
-adaptation;
-
-          [Q.] S. "special assessment" means a voluntary
-assessment imposed on a property pursuant to the Improvement
-Special Assessment Act for the total amount of special
-assessment financing together with interest, penalties, fees
-and charges related thereto;
-
-          [R.] T. "special assessment agreement" means a
-voluntary agreement of a property owner to allow a county to
-place an assessment on the owner's property to repay special
-assessment financing pursuant to the Improvement Special
-Assessment Act;
-
-          [S.] U. "special assessment assignable certificate"
-means a document assigning a special assessment lien from the
-county to a capital provider in an amount not to exceed the
-amount of the special assessment financing for the term of the
-special assessment lien;
-
-          [T.] V. "special assessment financing" means the
-total amount of financing provided by a capital provider
-pursuant to a special assessment financing agreement, including
-accrual of interest and penalties, charges, fees and costs of
-enforcement of a special assessment lien;
-
-          [U.] W. "special assessment financing agreement"
-means a contract pursuant to which a property owner agrees to
-repay a capital provider for special assessment financing and
-to the terms of the special assessment financing, including the
-treatment of prepayment and partial payment of a special
-assessment, servicing arrangements, the payment of any finance
-charges and fees and accrual of interest and penalties;
-
-          [V.] X. "special assessment lien" means a lien
-recorded in all counties in which the eligible property is
-located to secure the special assessment, which assessment
-remains on the property until paid in full;
-
-          [W.] Y. "uniform assessment documents" means the
-forms of county ordinance, special assessment agreement,
-special assessment lien, special assessment assignable
-certificate and other model documents prepared by the
-department pursuant to the Improvement Special Assessment Act
-for use in the program; provided, however, the department shall
-not mandate a form of special financing agreement that shall be
-supplied by a capital provider; and
-
-          [X.] Z. "water conservation improvement" means
-measures, equipment or devices that decrease the consumption of
-or demand for water, address safe drinking water or eliminate
-lead from water used for drinking or cooking."
-
-     SECTION 2. Section 4-55D-5 NMSA 1978 (being Laws 2023,
-Chapter 150, Section 5) is amended to read:
-
-     "4-55D-5. IMPOSITION OF SPECIAL ASSESSMENT--AMOUNT--COLLECTION--SPECIAL ASSESSMENT LIEN CREATED.--
-
-          A. Upon entering into a special assessment
-agreement, the county shall record a special assessment lien on
-the subject property in the real property records of the county
-in which the property is located.
-
-          B. The recording of the lien pursuant to Subsection
-A of this section shall include:
-
-                (1) the legal description of the property;
-
-                (2) the county assessor's parcel number of the
-property;
-
-                (3) the grantor's name, which shall be the
-same as the property owner on the special assessment agreement;
-
-                (4) the grantee's name, which shall be the
-county in which the property is located;
-
-                (5) the date on which the special assessment
-lien was created;
-
-                (6) the principal amount of the special
-assessment lien;
-
-                (7) the terms and length of the special
-assessment lien; and
-
-                (8) a copy of the special assessment
-agreement.
-
-          C. A special assessment lien shall be effective
-during the period in which the special assessment is imposed
-and shall have priority superior to all liens, claims and
-titles except a lien for general ad valorem property taxes or
-an improvement district lien that is coequal to property taxes.
-
-          D. A special assessment lien runs with the land,
-and that portion of the special assessment lien that has not
-yet become due is not accelerated or eliminated by foreclosure
-of the special assessment lien or any lien for taxes or
-assessments imposed by the state, a local government or taxing
-district against the property on which the special assessment
-lien is imposed.
-
-          E. A special assessment shall be paid by a property
-owner unless the property is under an industrial revenue bond
-lease, in which case the lessee shall pay the special
-assessment, but under no circumstance shall a local government
-pay a special assessment.
-
-          [E.] F. Upon entering into a special assessment
-agreement, the county shall execute and record a special
-assessment assignable certificate from the county to the
-appropriate capital provider. The special assessment
-assignable certificate shall convey the special assessment lien
-including all of the characteristics described in Subsection B
-of this section. The holder of the special assessment
-assignable certificate shall be solely responsible for the
-billing and collection of the related special assessment and
-for the enforcement of the special assessment lien.
-
-          [F.] G. When the underlying special assessment
-financing has been satisfied, the special assessment shall be
-removed from the property and the county shall record a release
-of the special assessment lien."
-
-     SECTION 3. Section 4-55D-7 NMSA 1978 (being Laws 2023,
-Chapter 150, Section 7) is amended to read:
-
-     "4-55D-7. SPECIAL ASSESSMENT FINANCING.--
-
-          A. Special assessment financing shall be provided
-by capital providers and disbursed directly by capital
-providers to fund eligible improvements subject to a special
-assessment financing agreement.
-
-          B. A county [is] or municipality shall not be
-liable in any way for the debt of the property owner [is] or
-the debt of the special assessment financing, shall not be a
-third-party obligor and [is] shall not [pledging] pledge or
-[lending] lend its credit to the property owner, [or] the
-capital provider or the special assessment financing."
-
-     SECTION 4. Section 4-55D-10 NMSA 1978 (being Laws 2023,
-Chapter 150, Section 10) is amended to read:
-
-     "4-55D-10. IMMUNITY.--Nothing in the Improvement Special
-Assessment Act shall be interpreted to pledge, offer or
-encumber the full faith and credit of a county or
-municipality."
-
-- 9 -
+IT/dw/sgs

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