Fixed grid fees

NESP 2026, Public Consultation Submission Submitted by: Eugenie Simmons, Sandys Parish, Bermuda Dear Minister, Thank you for the opportunity to comment on the NESP 2026 consultation. I am a homeowner in Bermuda. This policy will shape energy costs and energy independence on this island for a generation, and I believe it deserves to be tested against the evidence. 1. RISING BILLS HAVE A STRUCTURAL CAUSE THAT THE POLICY DOES NOT ADDRESS Electricity bills rise when fixed infrastructure costs are shared among fewer customers. Population changes, the prolonged closure of major commercial facilities, and island-wide efficiency improvements have all reduced total electricity consumption in recent years. Distributed solar generation (rooftop and ground-mounted) accounts for roughly 3% of Bermuda's total electricity supply. It is not, and cannot be, the primary cause of rising tariffs. The Fuel Adjustment Rate, the variable fuel cost component on every customer's bill, is the single largest driver of bill variability. It rises and falls with global energy prices. The draft policy does not explain how a transition to LNG would reduce this exposure, given that LNG is subject to the same global market forces as oil. I urge the Ministry to commission a clear, public analysis of what is actually driving demand decline before finalizing the policy. 2. LNG HAS ALREADY BEEN EXAMINED AND REJECTED — TWICE — FOR CLEAR REASONS Bermuda conducted two rigorous, independently reviewed Integrated Resource Planning exercises in 2019 and 2024. Both pointed away from LNG. The 2019 RA-approved IRP selected the non-LNG path, warning that an LNG commitment "would influence energy policy and prices for up to 50 years." LNG was only approximately 6% cheaper under base case assumptions, and a 25% increase in costs would reverse that advantage entirely. BELCO's own 2024 Preferred Plan also rejected LNG, selecting solar, battery storage, and other renewables instead. The history of the North Power Station is instructive: documents released under the Public Access to Information Act confirm that BELCO optimised that station for LNG without RA approval. When LNG was rejected, the resulting soot problems required a $2.4 million retrofit that the courts ruled could not be passed to electricity customers. The 2026 Iran conflict and Strait of Hormuz closure, characterised by the International Energy Agency as the largest energy supply disruption in global history, demonstrated precisely why isolated island nations cannot commit their energy future to any single imported fossil fuel. I ask the Ministry to explain what new evidence justifies reversing two carefully considered planning decisions. 3. CAPITAL MUST BE INVESTED IN FLEXIBLE SOLUTIONS, NOT LOCKED INTO FOSSIL FUEL INFRASTRUCTURE Under Bermuda's regulatory framework, every dollar of approved capital investment earns a guaranteed return recovered from electricity bills for the life of that asset, potentially 30 years or more. Capital committed to LNG infrastructure will earn that return regardless of whether better and cheaper alternatives emerge. The same capital directed toward battery storage, smart grid technology, time-of-use pricing systems, and demand management would create flexible, upgradeable assets whose costs are falling year on year. Capital committed to LNG cannot be redirected when better solutions become available. Capital invested in flexible technologies retains that option. Bermuda's policy should direct ratepayer investment toward the future, not lock it into a fossil fuel decision made in 2026. I urge the Ministry to require any proposed LNG investment to be explicitly evaluated against equivalent capital invested in modern, flexible alternatives. 4. RENEW THE COMMITMENT TO CLEAN ENERGY WITH THE TOOLS TO DELIVER IT Bermuda's own analysis shows 59% renewable electricity is achievable. The tools exist: solar at $0.072/kWh, rapidly improving battery storage (now cheaper than new gas plants, BloombergNEF, February 2026), island-wide smart meters already installed, and time-of-use pricing that incentivises demand shifting. What has been missing is the implementation framework: land-use planning, a storage roadmap, and tariff reform that shares costs fairly among all customers. I urge the Ministry to commit to these mechanisms with defined timelines rather than reopening a fuel pathway its own planning has twice set aside. 5. THE EMISSIONS CASE FOR LNG DOES NOT HOLD UNDER PROPER MEASUREMENT Peer-reviewed research published in Energy Science & Engineering (Wiley, 2024) found that under a 20-year measurement timeframe, LNG's greenhouse gas footprint is 33% greater than coal. End-use combustion accounts for only 34% of LNG's total emissions; the remaining 66% comes from methane leakage during production, shipping, and regasification. Given Bermuda's vulnerability to near-term climate impacts, the 20-year lens is the appropriate one. The NESP 2026 specifies no emissions framework for evaluating any LNG proposal. 6. BERMUDA'S EXISTING INFRASTRUCTURE SUPPORTS SMARTER ALTERNATIVES TODAY BELCO's island-wide smart meter rollout is already complete. The data infrastructure for time-of-use pricing, demand response, and Virtual Power Plant coordination already exists. Bermuda's geography makes EV-based distributed storage uniquely viable: at 25% EV adoption, the island's vehicle fleet holds an estimated 56 MWh of available distributed storage, already exceeding Dr. Eugenie M. SiBELCO's planned 40 MWh grid battery investment. Hawaiian Electric, operating a comparable isolated island grid, demonstrated 40 MW of grid services from residential batteries, eliminating equivalent new generation investment. Sincerely, Eugenie Simmons tsunami@btcnet.bm