
Janie Brown•3 weeks ago NESP 2026, Public Consultation SubmissionSubmitted 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 onthis 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 Xyears and have seen electricity bills rise significantly over that time."]---1. RISING BILLS HAVE A STRUCTURAL CAUSE THAT THE POLICY DOES NOT ADDRESSElectricity bills rise when fixed infrastructure costs are shared among fewer customers. Populationchanges, the prolonged closure of major commercial facilities, and island-wide efficiency improvementshave all reduced total electricity consumption in recent years. Distributed solar generation (rooftop andground-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 largestdriver of bill variability. It rises and falls with global energy prices. The draft policy does not explain how atransition to LNG would reduce this exposure, given that LNG is subject to the same global market forcesas oil.I urge the Ministry to commission a clear, public analysis of what is actually driving demand declinebefore finalising policy.---2. LNG HAS ALREADY BEEN EXAMINED AND REJECTED — TWICE — FOR CLEAR REASONSBermuda conducted two rigorous, independently reviewed Integrated Resource Planning exercises in2019 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." LNGwas only approximately 6% cheaper under base case assumptions, and a 25% increase in costs wouldreverse that advantage entirely.BELCO's own 2024 Preferred Plan also rejected LNG, selecting solar, battery storage, and otherrenewables instead. The history of the North Power Station is instructive: documents released under thePublic 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 ruledcould not be passed to electricity customers.The 2026 Iran conflict and Strait of Hormuz closure, characterised by the International Energy Agency asthe largest energy supply disruption in global history, demonstrated precisely why isolated island nationscannot commit their energy future to any single imported fossil fuel.I ask the Ministry to explain what new evidence justifies reversing two carefully considered planningdecisions.---3. CAPITAL MUST BE INVESTED IN FLEXIBLE SOLUTIONS, NOT LOCKED INTO FOSSIL FUELINFRASTRUCTUREUnder Bermuda's regulatory framework, every dollar of approved capital investment earns a guaranteedreturn recovered from electricity bills for the life of that asset, potentially 30 years or more. Capitalcommitted to LNG infrastructure will earn that return regardless of whether better and cheaperalternatives 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 onyear. Capital committed to LNG cannot be redirected when better solutions become available. Capitalinvested in flexible technologies retains that option.Bermuda's policy should direct ratepayer investment toward the future, not lock it into a fossil fueldecision made in 2026. I urge the Ministry to require any proposed LNG investment to be explicitlyevaluated against equivalent capital invested in modern, flexible alternatives.---4. RENEW THE COMMITMENT TO CLEAN ENERGY WITH THE TOOLS TO DELIVER ITBermuda'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 incentivisesdemand shifting. What has been missing is the implementation framework: land-use planning, a storageroadmap, 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 fuelpathway 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 MEASUREMENTPeer-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-usecombustion accounts for only 34% of LNG's total emissions; the remaining 66% comes from methaneleakage during production, shipping, and regasification. Given Bermuda's vulnerability to near-termclimate impacts, the 20-year lens is the appropriate one. The NESP 2026 specifies no emissionsframework 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 TODAYBELCO's island-wide smart meter rollout is already complete. The data infrastructure for time-of-usepricing, demand response, and Virtual Power Plant coordination already exists. Bermuda's geographymakes EV-based distributed storage uniquely viable: at 25% EV adoption, the island's vehicle fleet holdsan estimated 56 MWh of available distributed storage, already exceeding BELCO's planned 40 MWh gridbattery investment. Hawaiian Electric, operating a comparable isolated island grid, demonstrated 40 MWof grid services from residential batteries, eliminating equivalent new generation investment.Sincerely,Dr. Janie Brown10 Chapel LanePaget, PG02May 22,2026