New Belco Policy

NESP 2026, Public Consultation Submission

Submitted by: [Your Full Name], [Your Address]

Dear Minister,

Thank you for the opportunity to comment on the NESP 2026 consultation. I am a [homeowner /

business owner / resident] 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.

[Optional: add one sentence here about your personal connection, e.g. "I have lived in Bermuda for X

years and have seen electricity bills rise significantly over that time."]

---

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 finalising 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.

---

[OPTIONAL: include Point 5 if you wish to address emissions]

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.

---

[OPTIONAL: include Point 6 if you wish to address smart grid technology]

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 BELCO'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,

Dr. Janie Brown

10 Chapel Lane

Paget, PG02

May 22,2026