Can Bermuda Afford an Oil-Based Future? SolarX's Response to NESP 2026 and the Case for a Bermudian Clean Grid

SolarX Limited

Response to the National Electricity Sector Policy of Bermuda

(NESP 2026), Consultation Draft, April 2026

Submitted to: Ministry of Home Affairs, Department of Energy, Government of Bermuda

Submitted by: SolarX Bermuda

Date: 20th May 2026

Summary

As you read this document, we ask you to ask yourself one question – can Bermuda afford an Oil based future?

Bermuda stands at a generational choice point. We can keep burning imported oil that drains roughly $91M a year from the island economy, drives some of the highest electricity bills in the developed world, and contributes to measurable harm to the lungs of children growing up next to the North Power Station. Or we can choose, through NESP 2026 and the decisions that follow it, to keep that money on island, in Bermudian wages, Bermudian businesses and Bermudian futures.

The technology question is already settled. Solar paired with storage is the lowest cost source of new electricity available to Bermuda today. The BELCO IRP, the Regulatory Authority's own work, the University of Edinburgh independent review and the SolarX project-level model all converge on the same answer. What remains is a policy question and an equity question. Who gets to benefit, how quickly and at whose cost.

NESP 2026 answers those questions better than any energy policy Bermuda has produced. It places affordability and a just transition alongside decarbonisation as first principles. It opens the door, through the Community and Cooperative Energy Licence, to renters, condominium owners and public-housing families who have until now been locked out of solar entirely. It treats third-party ownership and on-bill financing as the mechanisms that let households and small businesses access clean power with no upfront capital. With the refinements set out in this response, it becomes a framework Bermuda can actually deliver.

The prize is large and concrete. The BELCO IRP preferred portfolio of 76 MW of solar plus 60 MW of offshore wind would retain approximately $47M per year on island, reduce bills for the average household and small business, create roughly 150 Bermudian jobs in construction and operations, and begin to lift the public-health burden carried disproportionately by residents of Pembroke. Over the lifetime of NESP 2026 the cumulative GDP impact runs into the billions of dollars.

The jobs opportunity is a generational one. Every megawatt of installed solar in Bermuda represents skilled, well-paid green jobs that cannot be offshored: electricians, structural trades, project managers, monitoring and maintenance technicians, EV-charging specialists, energy-storage engineers and community-engagement roles. SolarX's active pipeline alone supports approximately 100 temporary construction roles and 50 permanent operations and service roles, all Bermudian-first and delivered through partnership with the BIU and local training providers. Scaled to the BELCO IRP preferred portfolio, Bermuda has the chance to build an indigenous clean-energy workforce, with NCAB-certified apprenticeships, a structured pathway for young Bermudians into the trades, and a credible career alternative to financial services and hospitality. Green jobs in Bermuda are not an abstraction. They are work the island needs done, paid for in dollars that stay on island, building the skills the next generation will need to maintain, repair and expand the system long after the policy itself is signed.

The cost of delay is equally concrete. Every year Bermuda hesitates is roughly 600,000 MWh of avoidable oil burn, approximately $91M of foreign exchange sent overseas instead of paid to Bermudians, and another cohort of children who breathe air that exceeds World Health Organization limits. Energy policy is rarely framed in these terms. It should be.

SolarX exists to deliver exactly the outcomes NESP 2026 asks the private sector to deliver: affordable power, equitable access, Bermudian jobs, international capital deployed on island and oil displaced megawatt by megawatt. We are ready to commit our first community-cooperative pilot within eighteen months of the Community and Cooperative Energy Licence becoming operational. We are ready to back the proposed Government Renewable Energy Debt Guarantee Facility with our own project pipeline. We are ready to do this work in partnership with the Department, the Regulatory Authority, BELCO, the BIU, the BEDC and the wider community.

The decisions taken in the next three months will shape what Bermudian children inherit. A grid still tied to imported oil, with bills that rise with every fuel shock and air that fails international standards. Or a grid increasingly powered by sunshine that falls free on the island, owned in part by the community, paying Bermudian wages and leaving cleaner air behind. The opportunity to choose the second path is in front of us now, and the policy framework to deliver it is on the table. We urge the Ministry, the Department and the Regulatory Authority to take it.

1. Who we are

SolarX is a new and developing Bermudian social entrepreneurship venture, structured as a profit-with-purpose vehicle of the Ignite Bermuda charitable accelerator and capitalised through international climate finance. We exist to do three things for this island:

• Create Bermudian jobs. Our active pipeline alone supports approximately 100 temporary construction roles and 50 permanent operations, maintenance, monitoring and EV service roles.
• Cut the cost of electricity for Bermudian institutions and households. Under our 20-year lease structure, the customer’s effective cost of solar generation averages approximately $0.21/kWh over the project life, against a projected BELCO commercial blended rate averaging approximately $0.49/kWh over the same period. This represents a lifetime saving of approximately 58 percent for the customer, with zero upfront capital required. Year-one effective customer cost is approximately $0.38/kWh against a current BELCO commercial blended rate of approximately $0.40/kWh; the customer benefit grows year on year as the BELCO retail rate escalates while the SolarX lease remains fixed for the financed period and falls to operations and maintenance only thereafter.
• Reduce Bermuda’s exposure to imported oil. Every megawatt we deploy directly displaces fuel oil, reducing the foreign exchange outflow, fuel adjustment volatility, and public health burden that oil-fired generation imposes on every household and business in Bermuda.

SolarX is, in short, a vehicle purpose-built to deliver exactly the outcomes NESP 2026 asks the private sector to deliver: affordability, equity, resilience, and decarbonisation, with Bermudian jobs and Bermudian capital participating in every project.

The economics summarised above are drawn from the SolarX Public Cost-of-Energy Analysis (Echo, May 2026), a project-level financial model anchored on a fully specified 109.56 kW commercial deployment and scaled across credible pipeline scenarios. The underlying workings, including BELCO 2026 tariff assumptions, fuel displacement, public health and grid cost-recovery effects, are available to the Department of Energy on request.

We commend the Ministry, the Department of Energy and the Regulatory Authority for producing a pragmatic, technology-agnostic, least-cost framework that places affordability and a just transition alongside decarbonisation. The explicit endorsement of third-party ownership, on-bill financing, the BGSUI Licence and the new Community and Cooperative Energy Licence is the single biggest policy step Bermuda has taken on energy in a decade.

The remainder of this response sets out, with data, why oil must become Bermuda’s fuel of the past, addresses directly the public-interest concerns raised about distributed solar, quantifies the macroeconomic and public-health drag from continued oil dependence, and proposes a Government-backed debt guarantee facility as the single policy instrument with the highest leverage on overall cost of power.

2. The case for ending Bermuda’s dependence on imported oil

The data in NESP 2026 itself, taken together with publicly available BELCO IRP, Regulatory Authority and Department of Statistics figures, makes the case clear.

Four conclusions follow:

1. Oil is the single largest driver of Bermuda’s affordability problem. Tariff reform alone cannot fix this. The fuel itself must be displaced. BELCO’s own IRP modelling proves the point: their projected solar LCOE of $0.072/kWh is approximately one fifth of current retail tariffs.
2. Solar plus storage is now the least-cost option for Bermuda. This is consistent with NESP 2026 Section 7.3.4, with the BELCO IRP, with the third-party review by Professor Aristides Kiprakis of the University of Edinburgh, and with global LCOE data. There is no credible scenario in which continued investment in oil generation produces lower long-term tariffs than an accelerated renewable build-out.
3. Solar must be paired with firm, dispatchable capacity. Bermuda’s island grid cannot retire oil credibly without a parallel policy track for utility-scale battery storage, long-duration storage, and an orderly displacement of legacy thermal plants. NESP 2026 and the BELCO IRP both reflect this; the remaining task is operationalisation at pace.
4. Speed matters. Each year of delay is approximately 600,000 MWh of avoidable oil burn, approximately $91M of avoidable foreign exchange outflow, public health costs detailed in Section 2A, and several hundred avoidable Bermudian jobs not created.

NESP 2026 should therefore be read not only as an electricity policy but as Bermuda’s economic security and public health policy. The actions below are framed with that in mind.

2A. Addressing the public-interest concerns raised about distributed solar

Recent public discourse has raised three concerns about the expansion of private distributed solar in Bermuda: that all generators should be cost-regulated; that every sector must carry its fair share of grid costs; and that those who can least afford electricity must not subsidise those who can. SolarX takes each of these concerns seriously, agrees with the principle behind each, and sets out below an evidence-based response.

On regulatory oversight

SolarX supports proportionate, evidence-based oversight of private generators within the Regulatory Authority’s existing remit. The appropriate regulatory tools for behind-the-meter customer-owned generation are the Innovative Licence (NESP 2026 Section 4.6) and the DG tariff methodology referenced in Section 8.1, not utility-style cost-of-service regulation, which is designed for monopoly assets serving a captive customer base. We endorse a transparent BGSUI export tariff (Comment 1), the phased DG tariff reform with grandfathering set out in Comment 4, and the resale framework in Comment 8 that brings third-party PPAs, leases and community energy explicitly under RA oversight.

On grid cost recovery

Distributed solar reduces BELCO’s variable fuel costs in proportion to the kWh displaced, but does not by itself reduce BELCO’s fixed costs (generating capacity, transmission, distribution, system services). Under the current tariff methodology, those fixed costs are recovered through a per-kWh charge that scales down with reduced sales. This creates a real, if modest, cross-subsidy effect from non-solar to solar customers at scale.

SolarX has modelled this effect explicitly. At the indicative DG growth scenario in Section 5.1 (approximately 40 MW by 2045), the per-kWh cost-recovery impact on non-solar ratepayers under the current tariff structure is in the order of 0.5 to 1.0 cents per kWh, equivalent to between 1 and 2 percent of the current commercial blended rate. This is real but modest in absolute terms and is fully addressable through the demand-charge and standby-charge reforms anticipated in Section 8.1 and through the DG tariff methodology consultation set out in Comment 4.

Set against this, the BELCO IRP’s preferred portfolio (76 MW solar plus 60 MW offshore wind by the late 2020s, displacing 52 percent of current demand) would save Bermuda approximately $47M per year in foreign exchange outflow at current fuel prices, accruing to the island economy regardless of who owns the generating asset. The cumulative 20-year fuel displacement at this scale is in the order of $940M, plus avoided emissions of approximately 4.9 million tonnes of CO2 against the BELCO grid intensity. These are island-level economic gains, not transfers between ratepayer classes.

The policy implication is straightforward: the cross-subsidy concern is real and should be addressed through tariff reform, not by restricting access to a technology that produces material island-wide economic value. The two policy tracks (tariff modernisation and DG acceleration) must run in parallel; they are not alternatives.

On equity

The concern that distributed solar to date has disproportionately benefited property owners is real and well-founded under the current product mix. SolarX agrees this is a problem that must be addressed actively, not waved away. The Community and Cooperative Energy Licence (NESP 2026 Section 6.2) is the direct policy instrument that resolves it. By enabling renters, condo dwellers and the Government’s public housing solar initiative (announced March 2026) to participate in solar economics, the Licence reframes solar from a property-owner benefit to a universal one.

SolarX commits to supporting its first community project as a public-housing or condo cooperative pilot within 18 months of the Community and Cooperative Energy Licence becoming operational, on the basis of fundable and scalable models being in place. This is the kind of targeted, equity-led deployment that should sit alongside, not be displaced by commercial rooftop projects.

The Bermudian policy conversation should not be framed as a binary choice between protecting non-solar ratepayers and accelerating renewables. Both objectives are achievable if pursued in parallel through (a) tariff modernisation, (b) accelerated community and cooperative deployment, and (c) the regulated energy services delivery framework set out in Comment 8.

2B. The macroeconomic and public-health cost of continued oil dependence

Beyond the customer-level affordability case, continued oil dependence imposes two further costs on Bermuda that are not fully captured in BELCO’s tariffs. Both should inform NESP 2026 implementation priorities.

Macroeconomic drag from fuel imports

BELCO’s 2026 fuel adjustment rate of $0.1378/kWh, applied to the IRP’s 660,000 MWh annual demand, implies an annual fuel import bill of approximately $91M. Against the Department of Statistics 2024 GDP figure of $7.1 billion, that is approximately 1.3 percent of GDP leaving the island every year, purely to import the fuel BELCO burns. Cumulatively over the 20-year IRP horizon, this is approximately $1.8 to $2.7 billion of foreign exchange outflow depending on fuel-cost escalation assumptions.

This is gross outflow. The economic drag is larger when local multiplier effects are considered. Money spent on imported fuel does not circulate domestically; it does not pay Bermudian wages, does not generate payroll tax receipts, does not support local businesses. Conservative small-island economic multipliers of approximately 1.5 to 2.0 imply an annual GDP impact in the order of $140M to $180M, or approximately 2 percent of GDP, sustained year after year.

Bermuda’s 2024 Annual GDP report (Department of Statistics) noted that economic growth was led by International Business and Local Business activity, with broad-based resilience across most sectors. That growth is achieved despite, not because of, the structural fuel-import drag. Eliminating or materially reducing that drag is the single largest macroeconomic lever available to Government through energy policy.

Against this backdrop, the BELCO IRP’s preferred portfolio (76 MW solar plus 60 MW offshore wind, displacing approximately 52 percent of demand) would retain approximately $47M per year on island in current dollars, with a 20-year cumulative impact in the order of $940M before multiplier effects, or approximately $1.6 billion of cumulative GDP impact after multipliers. That is a Bermudian economic-development case, independent of climate or affordability arguments.

Public health cost of oil-fired generation

BELCO’s North Power Station has been the subject of sustained public health concern. Documented findings in the public record over 2022 to 2026 include:

• Bermuda’s annual mean PM2.5 concentration exceeds the WHO recommended maximum (Travel Doctor Network, citing WHO data).
• 63 exceedances of the UK Air Quality Objective for sulphur dioxide were recorded at a single Ocean Lane monitoring station within one year (Royal Gazette, 14 November 2022), compared with the UK maximum of 35 per year. The Bermuda Clean Air Coalition estimates that exceedances would be “dramatically higher” if monitoring were extended in a full 360-degree arc around the plant.
• Ricardo Energy & Environment, the UK-based environmental consultancy, found that polluting events from the North Power Station are likely caused at least in part by the plant’s operating characteristics (Royal Gazette, January 2024).
• The Bermuda Clean Air Amendment Act 2024 introduced legally binding limit values for ambient air pollutants, drawing on WHO and US EPA standards; enabling regulations remain pending (Royal Gazette, August 2025).
• In August 2025, Minister of Economy and Labour the Hon. Jason Hayward, the sitting MP for Pembroke Central, stated publicly that BELCO “was not making the health and safety of residents a priority” and called for accelerated long-term solutions to soot emissions (Royal Gazette, 5 August 2025). “Environmental justice is not optional, it is a fundamental right.”
• Under Section 4 of the Public Health Act 1949, the Minister of Health holds the legal power to declare ongoing emissions a “statutory nuisance” and require abatement (Royal Gazette, March 2023).

Bermuda has not yet commissioned a comprehensive epidemiological study quantifying the health cost of North Power Station emissions, and SolarX does not seek to put a precise dollar figure on those costs without one. The Bermuda Health Council has indicated such a study “could be explored”. We urge the Ministry of Health and the Department of Environment and Natural Resources to commission such a study as part of NESP 2026 implementation, since the result would directly inform the social cost of carbon and fuel-displacement valuation used in future IRPs.

What is already clear is directional: continued oil-fired generation in a densely populated jurisdiction imposes real, measurable, and politically acknowledged health costs on Bermudian residents, particularly in the communities immediately around the North Power Station. Every megawatt of distributed solar that displaces marginal HFO/diesel generation is a megawatt of public-health benefit, on top of the customer-affordability and fuel-displacement benefits already quantified. This is a third independent reason to accelerate renewable deployment, alongside affordability and climate.

3. Priority comments and recommended actions

Comments are keyed to NESP 2026 section numbers.

Comment 1. Section 4.5 BGSUI. Set a transparent, economically meaningful BGSUI export tariff.

The draft states that BGSUI feed-in tariffs “shall not increase rate pressure for other consumers.” SolarX fully supports cost-reflective tariff design. However, a feed-in tariff set at zero or at a punitive level would prohibit use of the 30 percent export provision, undermining the BGSUI Licence and forcing right-sized systems to be undersized.

Action: The Regulatory Authority should publish, within 12 months of NESP 2026 adoption, a transparent BGSUI export methodology set at no less than the Utility’s avoided bulk generation cost (fuel plus variable O&M), with locational and time-of-day adjustments published. This honours the no-cross-subsidy principle while preserving an economic signal for right-sized design.

Comment 2. Section 6.1 Access and financing. Confirm solar leases and PPAs as qualifying third-party ownership and on-bill financing.

Section 6.1 names third-party ownership, on-bill financing and green financing as the mechanisms that will deliver DG to households and SMEs without upfront capital. Without explicit confirmation, banks and BEDC cannot underwrite it.

Action: The final NESP should explicitly state: (1) Solar leases and power purchase agreements are qualifying third-party ownership models. (2) The Utility, in coordination with the RA, will operationalise on-bill financing within 12 months of adoption, under which an approved provider’s lease or PPA charge can be settled alongside the customer’s BELCO bill. (3) The on-bill mechanism will be available to BGSUI, DG, and Community and Cooperative Energy projects.

This single clarification unlocks Bermudian bank lending, BEDC co-lending, and international climate finance against a bankable structure. It also depends on, and should be sequenced with, the energy services resale framework set out in Comment 8 and the Government guarantee facility proposed in Comment 10.

Comment 3. Sections 3.1 and 4.5. Standardise BGSUI access to Government land and rooftops.

The offer of Government land and seabed at low cost (Section 3.1) is material. In practice, projects on public land currently require bespoke multi-ministerial negotiation that imposes disproportionate transaction cost on small, high-impact projects.

Action: The Department of Energy should, within 12 months, publish: (1) A standard template BGSUI site licence and lease for Government-owned sites. (2) A pre-cleared list of Government-held rooftops, parking structures and unused parcels suitable for renewable development (target 20 sites in the first list). (3) A transparent, competitive application process with a fixed 90-day decision timeline. (4) A pilot allocation in 2026 to one Bermudian social enterprise vehicle (such as SolarX) to prove the template at speed and at no cost to the Government.

Comment 4. Section 8.1 Tariff structures. Phase DG tariff reform and grandfather contracted projects.

SolarX agrees that the existing tariff methodology contains structural cross-subsidies, as set out in Section 2A above. However, abrupt or retroactive reform will collapse private investment in DG and stall the renewable build-out the policy depends on. The right approach is parallel-track: tariff modernisation and DG acceleration moving together, not sequentially.

Action: (1) The RA should publish a full DG tariff reform consultation, with impact modelling, before any methodology change is adopted. (2) Systems installed under, or contracted against, the prevailing tariff methodology at the date of NESP 2026 adoption should be grandfathered for a minimum of 10 years. (3) New DG charges (grid access, standby) should be phased over a defined glide path, not imposed in a single step. (4) The consultation should explicitly consider rebalancing fixed-cost recovery from volumetric per-kWh charges toward demand charges and standby charges, which more accurately reflect the cost causation of grid services.

Comment 5. Section 6.2 Community and Cooperative Energy Licence. Publish regulations on an accelerated timeline.

The Community and Cooperative Energy Licence is the right instrument to extend renewable access to renters, condo dwellers and small businesses, who today are entirely excluded from solar. This is the direct policy answer to the equity concern set out in Section 2A. SolarX, working through the Ignite Bermuda accelerator, is ready to develop qualifying projects as soon as the framework is operational and commits to a public-housing or condo cooperative pilot within 18 months of Licence operationalisation. Community projects also depend on the resale framework in Comment 8 to be commercially viable.

Action: The Department of Energy and the RA should publish draft eligibility criteria, licence conditions and technical standards within 9 months of adoption. A first licensed community project should be commissioned within 18 months.

Comment 6. Section 4.6 Innovative Licence. Confirm bundled solar plus battery plus EV as a single licence.

The Innovative Licence regime (7 years plus 5-year extension) is well designed to pilot integrated behind-the-meter offerings. It is unclear whether a bundled customer-sited offering (rooftop PV plus battery plus managed EV charging) qualifies for a single Innovative Licence, or requires parallel BGSUI / DG / retail treatment. This question is partially resolved by, and should be sequenced with, the resale framework in Comment 8.

Action: The RA should publish guidance, within 12 months, confirming that integrated behind-the-meter bundles qualify for a single Innovative Licence, with a defined pathway to transition proven elements into standing licence classes at end of term.

Comment 7. Section 10.1 Installer licensing. Mutual recognition of NCAB, NABCEP and ETA International.

SolarX strongly supports a skilled, safe, nationally coordinated installer workforce. Requiring duplicate certification creates friction that delays projects and inflates cost without improving safety, while restricting the supply of qualified Bermudian electricians who could otherwise be cross-trained.

Action: The Electricity Act amendments anticipated in Section 12.2 should establish: (1) Mutual recognition between NCAB certification and NABCEP / ETA International credentials for the relevant scope of PV work. (2) A short bridging module for practitioners moving between frameworks. (3) A public registry of accredited installers updated quarterly. (4) An apprenticeship pipeline aligned with the Photovoltaic Workforce Development Pathway in Section 10.3.1, targeting 50 newly certified Bermudian PV electricians by 2028.

Comment 8. Section 9.3 Electricity resale. Enable a regulated energy services delivery framework, with EV charging as the first use case.

The current prohibition on electricity resale is the single largest binding constraint on a wide class of private investment. It blocks not only commercial EV charging, but also community solar, multi-tenant and campus energy services, third-party PPAs, and the on-bill financing model in Comment 2. Tackling these one at a time through sequential legislative amendments will lose years that NESP 2026’s 2030 and 2035 targets do not have.

Action: The Ministry should commit to tabling, within 12 months of adoption, an Electricity Act amendment establishing a regulated energy services delivery framework that: (1) Permits an authorised provider to deliver electricity to an end customer as part of a bundled service (lease, PPA, charging, community membership), under RA oversight. (2) Covers, at minimum, EV charging, community and cooperative energy projects, third-party owned solar leases / PPAs (Comment 2), and integrated behind-the-meter bundles (Comment 6). (3) Establishes consumer protection, metering and billing standards aligned with the Innovative Licence regime. (4) Is supported by a dedicated EV tariff, including off-peak, published by the RA within 18 months of adoption.

A single legislative pass that opens this framework unlocks four NESP 2026 instruments simultaneously, rather than requiring four sequential rounds of primary legislation.

Comment 9. Section 5.1 IRP input assumptions. Model policy-supported DG growth, not historical organic uptake.

The policy’s projection of approximately 35 MW incremental DG by 2045 (Section 3.3.2) is conservative against the trajectory Sections 6.1 and 6.2 will produce if their financing and licensing instruments are operationalised at pace. Understated DG assumptions will lead to overbuilt centralised oil generation and higher long-term tariffs.

Action: The IRP input assumption process (Section 5.1) should model two DG growth scenarios:

• (a) status quo organic uptake;
• (b) policy-supported uptake with third-party ownership, on-bill financing, Community and Cooperative Energy Licences fully operational, the Government guarantee facility (Comment 10) deployed, and BGSUI access to Government land standardised.

The higher of the two should inform least-cost portfolio selection in the absence of evidence to the contrary.

Comment 10. Government Renewable Energy Debt Guarantee Facility. Establish a fiscally responsible contingent-liability facility to accelerate deployment and reduce cost of power.

Of all the policy instruments available to Government within the NESP 2026 framework, a government-backed debt guarantee facility for qualifying renewable energy projects offers the highest leverage on overall cost of power. The case rests on four points.

First, a guarantee is a contingent liability, not a cash outlay. The Treasury’s exposure crystallises only on project default. Bermudian solar PV projects with creditworthy commercial off takers (Government departments, hospitals, hotels, schools, financial institutions) have low expected default rates over a 20-year horizon. On a $200M portfolio guaranteed at 50 percent, expected loss at industry-standard default and recovery assumptions is in the order of $300,000 per year, well within fiscal capacity.

Second, the benefit is rating uplift. With a Bermuda Government partial credit guarantee, lenders price renewable debt at a sovereign-adjacent rate rather than a corporate-developer rate. This typically reduces the cost of debt by 200 to 400 basis points. Applied to a $200M deployment financed at 6 percent rather than 9 percent, the lifetime interest saving is in the order of $80M to $120M. That saving flows directly through to lower lease and PPA pricing, which means lower customer bills, which means lower overall cost of power for Bermuda.

Third, the facility can be sized against the macroeconomic gain it unlocks. As set out in Section 2B, the BELCO IRP preferred portfolio (76 MW solar plus 60 MW wind) saves Bermuda approximately $47M per year in fuel imports, or $940M cumulatively over 20 years. The Government can capture a meaningful share of this retained spending through payroll tax, customs duty on domestic capital goods, and reduced public health expenditure. A $200M guarantee facility that unlocks deployment of even half the IRP’s preferred portfolio would generate fiscal returns to Government several multiples greater than the expected loss on the guarantee itself. The facility is fiscally net-positive even before accounting for emissions and air quality benefits.

Fourth, the precedent is well established. The UK Treasury provides infrastructure guarantees through UK Guarantees Scheme and UK Export Finance. The US Department of Energy operates the Loan Programs Office with explicit Federal guarantees on renewable energy debt. The Caribbean Development Bank operates Climate Action Lines of Credit. The Green Climate Fund offers credit guarantees to small-island developing states. The Bermuda Government itself currently extends approximately $90M annually in indirect policy support to the electricity sector (per the RA’s 2024 reporting, BELCO has saved consumers $90M through revenue allowance adjustments since 2020, reflecting the scale of regulatory intervention in the sector). Redirecting a fraction of that policy support toward debt-guarantee instruments for renewable deployment is fiscally neutral at worst and positive at best.

Action: The Ministry of Finance, in coordination with the Ministry of Home Affairs and the RA, should establish within 6 months of NESP 2026 adoption a Bermuda Renewable Energy Debt Guarantee Facility (BREDGF) with the following design parameters:

1. Eligibility: Qualifying BGSUI, DG, Community and Cooperative Energy, and Innovative Licence projects, with priority for projects delivering against the BELCO IRP preferred portfolio targets.
2. Form: Partial credit guarantee at 50 to 70 percent of senior debt, on a portfolio rather than project basis to diversify Treasury risk.
3. Cap: Initial cap of $200M of guaranteed exposure, reviewable at the 36-month mark against deployment and default performance.
4. Pricing: Guarantee fee paid by the borrower at a level that covers expected loss plus an administrative margin, ensuring the facility is fiscally self-funding at expected loss rates.
5. Governance: Independent credit committee with majority non-Government membership, reporting annually to the Public Accounts Committee.
6. Equity overlay: A reserved sub-allocation (10 to 20 percent of facility size) for Community and Cooperative Energy Licence projects serving low-income households, public housing, and renter-cooperatives.
7. Multilateral co-guarantee option: Active pursuit of co-guarantee arrangements with Caribbean Development Bank, Green Climate Fund, or UK Export Finance to reduce Treasury exposure further.

This is the single policy instrument that most directly addresses BELCO President Wayne Caines’ challenge (Royal Gazette, 19 May 2026) for an “evidence-based” framework that delivers affordability “without shifting costs onto those least able to bear them.” A guarantee facility lowers customer costs through cheaper capital, accelerates deployment through bankability, includes an explicit equity sub-allocation, and is fiscally responsible because it is a contingent liability priced at expected loss. It is, in short, the policy answer to the question Caines posed.

4. What SolarX will deliver against this policy

SolarX is a recently formed business with a strong pipeline of customer interest including LOI's and partnership agreements, not a concept. We are sharing the following to give the Department concrete evidence that the policy framework above is immediately bankable.

The structure is Bermudian, the workforce is Bermudian, the savings stay in Bermudian pockets, and the risk sits with international capital, not with Bermudian taxpayers or ratepayers.

5. Points of strong agreement

SolarX particularly supports the following positions in the draft and urges their retention in the final NESP:

• Technology-agnostic, least-cost framework (Sections 1.1, 5.2)
• Prioritisation of solar and energy storage as the near to medium-term pathway (Section 7.3.4)
• Explicit offer of Government land and seabed for renewable development (Section 3.1)
• Creation of the Community and Cooperative Energy Licence class (Sections 4.9, 6.2)
• Requirement for IEC / UL / IEEE 1547 equipment standards (Section 10.2)
• Grid modernisation including BESS in the IRP roadmap (Sections 5.4, 8.2). We urge the Joint Committee to go further and treat utility-scale and long-duration storage as a first-order policy track in the next IRP cycle, with explicit capacity targets, procurement mechanism, and a defined role for storage in firming intermittent renewables and supporting multi-day resilience.
• Just Energy Transition workforce development via the Photovoltaic Pathway (Section 10.3.1)
• Adoption of Performance Based Regulation extended to renewable integration metrics (Section 8.5)

6. Summary of recommended actions and timelines

Delivery against this schedule, in the round, would put Bermuda firmly on track to displace oil as its primary generation fuel within the lifetime of NESP 2026.

7. Closing

NESP 2026 is a materially better policy than its predecessor and, with the refinements above, provides the framework Bermuda needs to deliver affordable, reliable, equitable and low-carbon electricity through 2045.

NESP 2026 sets affordability alongside decarbonisation as the policy’s first principle. Distributed solar, properly regulated and equitably deployed, is the only near-term mechanism that delivers both simultaneously. The fuel-displacement value alone (approximately $91M per year today, scaling to over $1.6 billion of cumulative GDP impact at full IRP preferred-portfolio deployment) justifies the policy direction; the customer-affordability and equity benefits, properly designed for through the actions above, make it the policy Bermuda needs.

The single biggest opportunity is to treat oil displacement not as a decarbonisation goal but as Bermuda’s most important economic security and public health policy of the decade. Every megawatt of Bermudian solar, financed by international capital and built by Bermudian hands, is foreign exchange retained on island, household bills reduced, public health improved, and risk taken off the public balance sheet.

The Government Renewable Energy Debt Guarantee Facility proposed at Comment 10 is the single policy instrument with the highest leverage on overall cost of power. It costs the Treasury little in expected terms, accelerates deployment substantially, and aligns directly with the BELCO IRP preferred portfolio. We urge its serious consideration.

Solar is necessary but not sufficient. Bermuda’s land constraint means rooftop solar alone cannot close the 76 MW gap; floating solar, onshore utility and a parallel storage and firm-capacity policy track must move in lockstep with distributed generation. NESP 2026 has the right instruments. The remaining task is to operationalise them at pace and as a system.

SolarX Bermuda is committed to delivering against this policy from day one. We would welcome a follow-up meeting with the Department of Energy and the Ministry of Finance to walk through these comments, share our project pipeline, financing approach, Bermudian workforce plan, the underlying cost-of-energy analysis, and the proposed BREDGF design parameters.

Yours faithfully,

Sean Reel

sean.reel@ignitebermuda.com

on behalf of SolarX Bermuda

This response is submitted in accordance with the public consultation process for the NESP 2026 Consultation Draft (April 2026) and before the 5pm, Thursday 21 May 2026 deadline. SolarX Bermuda reserves the right to supplement these comments with further written material during the consultation period. Non of the contents are a contractual obligation or indication of approved future actions. The underlying cost-of-energy analysis (SolarX Public Cost-of-Energy Analysis, Echo, May 2026) is available to the Department of Energy on request.