Book Power-Sector

POWER SECTOR
An Enigma with No Easy Solution

Edited By: Tahir Basharat Cheema, Nadeem Ul Haque and A�ia Malik
Research for Social Transformation & Advancement

Pakistan Institute of Development Economics, Islamabad
© RASTA-PIDE 2022
Published by Research for Social Transformation & Advancement (RASTA),

at the Pakistan Institute of Development Economics (PIDE),
Islamabad, PAKISTAN.
Tel. +92 (51) 9248144, 9248137

Email: rasta@pide.org.pk, publications@pide.org.pk
URL: www.pide.org.pk
ISBN 978-969-461-151-8
All rights reserved: No part of this publication may be reproduced, stored in a

retrieval system, distributed, or transmitted in any form or by any means,
including photocopying, recording, or other electronic or mechanical methods,
without the prior written permission of the RASTA-PIDE at the address above.
Book reviewed by Mr Anwar Kamal (Senior Advocate, Supreme Court of Pakistan,

and Former Advisor to the National Electric Power Regulatory Authority)
December 2022
i
TABLE OF CONTENTS
Table of contents ....................................................................................................................i

List of Figures .....................................................................................................................iv
List of Boxes ………………………………………………………………………………………………………vi
List of Tables ........................................................................................................................vii
List of Acronyms...................................................................................................................viii
Preface...................................................................................................................................xiii
Executive Summary.............................................................................................................xvi
Pakistan power sector (June 30, 2021)..............................................................................1
1. POWER SECTOR: PREMIER CHALLENGES ............................................................3
1.1. Financial Viability and Power Sector Losses .................................................3

1.2. Supply Reliability ...................................................................................................7
1.3. Unaffordable & Uncompetitive Tariffs ...........................................................12
1.4. Governance ............................................................................................................16
1.5. Corporate Governance and Management......................................................17
1.6. Lack of Coordinated Planning ..........................................................................20
1.7. Lack of Comprehensive Policy .........................................................................23
1.8. Expensive Fuel Mix: A Planning Failure .......................................................25
2. DISTRIBUTION CHALLENGES: WHY ARE DISCOS NOT DELIVERING?..........29
2.1. DISCO’s Major Challenges .................................................................................30

2.2. Poor Electricity Distribution Performance: Major Reasons ...................36
3. EXTERNALITIES AFFECTING ELECTRICITY DISTRIBUTION .........................47
3.1. Variation Across Distribution Companies ....................................................47

3.2. Externalities ..........................................................................................................47
4. PRIVATIZATION OF DISTRIBUTION COMPANIES_ A FUTILE EXERCISE? .....51
4.1. Privatization of Electricity Distribution in Pakistan: History ................52
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4.2. Lessons from K-Electric Privatization for Other Distribution
Companies .............................................................................................................54
4.3. Privatization of Monopoly ................................................................................54
5. GENERATION BLUES ...........................................................................................58
5.1. Introduction .........................................................................................................58

5.2. GENCOs: Historical Perspective .....................................................................61
5.3. Random Decision Making ................................................................................62
6. IPPS THAT CHANGED THE POWER ARCHITECTURE IN PAKISTAN ............64
6.1. Beginning of IPPs Era in Pakistan .................................................................65

6.2. Wrong Decisions and IPP Irregularities ......................................................67
6.3. Role of Several Parallel Entities .....................................................................72
7. POWER CONTROL AND ALLIED ISSUES ...........................................................75
7.1. Load Dispatch Center (LDC): History ...........................................................75

7.2. Transmission Constraints and Economic Merit Order ............................76
7.3. Upgradation of NPCC .........................................................................................79
7.4. SCADA and the Data Exchange Portal ...........................................................81
7.5. Power Breakdowns in the NTDC System .....................................................83
7.6. Delays in System Restoration after Blackouts: Reasons &
Solutions ..............................................................................................................86
8. ASSET MANAGEMENT AND PROCUREMENT IN POWER SECTOR ................88
8.1. Power Sector Procurement Process and Challenges ...............................88

8.2. Lack of Asset Management System in NTDC ..............................................92
9. POWER PLANNING: FAILURES OF THE LAST THREE DECADES ..................95
9.1. Introduction ........................................................................................................95

9.2. Distribution Planning: A Missing Link .........................................................95
9.3. Issues in Planning Process at the NTDC ......................................................98
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9.4. Failure of Last Three Decades.......................................................................100
10. REGULATORY AFFAIRS AND CONSUMER-END TARIFF DESIGN ................104
10.1. Establishment of NEPRA ...................................................................................104

10.2. Tariff Determination ...........................................................................................105
10.3. Consumer-end Tariff ...........................................................................................109
10.4. Load Suppression Tariff (Increasing Block Tariff ) Model ...................116
11. COMPETITIVE TRADING BILATERAL CONTRACT MARKET (CTBCM) .....123
11.1. Preface ..................................................................................................................123

11.2. CTBCM Primary Commercial Features .......................................................123
11.3. Current Market Structure: Single Buyer Model .......................................125
11.4. Wholesale Market Fundamentals .................................................................126
11.5. Distributed Generation (DG) and Wheeling of Power ..........................128
12. FUTURE ARCHITECTURE OF THE POWER SECTOR .....................................131
12.1. Managerial Reforms .........................................................................................131

12.2. Re-organize Power Institutions & Reduce Government Footprint....132
12.3. All-Inclusive Power Policy & Coordinated Planning ............................. 135
12.4. Establish a Power Commission .....................................................................135
12.5. Power Sector Revenue Recovery Plan ........................................................136
12.6. Technology and Power Sector Futures .......................................................137
12.7. Indigenous Energy for Future .......................................................................140
12.8. Energy Conservation and Ef�iciency ...........................................................145
Bibliography 147
Appendix A. Power Sector and Establishment of WAPDA 151
Appendix B: Why the Reforms of the 1990s Failed? 153
Appendix C. Senior Management Challenges 156
Appendix D. Power Commission 162
Appendix E. Power Sector Revenue Recovery Plan 163
iii
Appendix F(a). Regulatory Framework: NEPRA 167
Appendix F(b). Tariff Determination Procedure 169
Appendix F(c). Electricity Tariff in Pakistan: Historical Perspective 170
LIST OF FIGURES
Figure 1.1. Circular Debt Growth (Rs Billion) ……………………………......................3

Figure 1.2. Public Debt …………………………………………………………………………........5
Figure 1.3. Receivables (Rs Billion)…………………………………………………………......6
Figure 1.4. NTDC Peak Demand and Generation Capability (MW)..……………...8
Figure 1.5. KE Peak Demand and Generation Capability (MW)……………….......9
Figure 1.6. Installed Capacity, Maximum Generation Capability
and Peak Demand (MW) .........................................................................9
Figure 1.7. Average Loadshedding Hours………………………………………………..……11
Figure 1.8. Average Sale Price (Rs/KWh) …………………………………………………..13
Figure 1.9. Power Sector Subsidies (Rs Billion) ………………………………………...14
Figure 1.10. Average Sale Price (Rs/KWh) ……………………………………………….....15
Figure 1.11. Power Sector Governance Structure…………………………………………16
Figure 1.12. Installed Capacity (MW)…………………………………………………………..21
Figure 1.13. Installed Generation Capacity FY2022……………………………………..26
Figure 1.14. Fuel Cost (Rs/ KWh) in CPPA-G System…………………………………….27
Figure 1.15. Cost Invoiced by Generators Rs Billion (FY2022) …………………....28
Figure 2.1. T&D Losses (%) in FY2021……………………………………………………….31
Figure 2.2. T&D Losses in Million KWh in FY2021……………………………………..31
Figure 2.3. Transmission & Distribution Losses…………………………………………32
Figure 2.4. Percentage Recoveries in FY2021……………………………………………..33
Figure 2.5. Recovery Loss in Rs. Million (FY2021)……………………………………..33
Figure 2.6. Circle-wise % Recovery in PESCO (June 2021) ………………………...34
Figure 2.7. State of Distribution Infrastructure…………………………….................35
Figure 2.8. Number of Fatal Accidents………………………………………………………..36
Figure 2.9. Net Pro�it/ Loss after Tax (Rs Million) …………………………………….37
Figure 2.10. Shortages at LESCO……..……………………………….………………………….40
Figure 2.11. IESCO Organogram…………………………………………………………………..41
iv
Figure 2.12. Pre-paid Smart Metering System ..……………………………………….....45
Figure 3.1. District-wise Mapping of Human Development Index (HDI) ……48
Figure 3.2. District-wise Mapping of Power Sector Operations ……..………….. 49
Figure 3.3. District-wise Mapping of Per Capita Income ..………..……………… 49
Figure 3.4. District-wise Mapping of Governmental Writ …………..…………… 50
Figure 4.1. Pre-requisites for Successful Privatization of
Electricity Distribution ..…..………........................................................51
Figure 6.1. Installed Capacity (MW) ..………………………………………………………..64
Figure 6.2. Generation Capacity (GWh)…………………...……………………………......65
Figure 7.1. Facilities under the Upgraded Project ……………………………………..76
Figure 7.2. NPCC has been Performing as System Operator (SO);
SO is Responsible for .…….....................................................................77
Figure 7.3. Power System Managed by NTDC …………………………………………....78
Figure 7.4. Data Management Opportunities Included in LDS Phase-II ….....80
Figure 7.5. LDS Phase-III Project ………………………………………………………….…..81
Figure 7.6. Causes of Power Blackouts ……………………………………………………….83
Figure 7.7. Analysis …………………………………………………………………………………..84
Figure 10.1. Tariff Structure ……………………………………………….……………………106
Figure 10.2. NEPRA Tariff Regimes ………………………………………………….…….…108
Figure 10.3. Anomalies in Tariff Calculation ……………………………………….…..109
Figure 10.4. Consumer-end Tariff (Rs/KWh) FY2020 ………………………….…..110
Figure 10.5. Electricity Bill Dissection ………………………………………………….….113
Figure 10.6. Residential Tariff Slabs (Rs/ KWh) …………………………………………115
Figure 10.7. Agriculture Tariff (Rs/ KWh) ……………………………………….………..115
Figure 10.8. Industrial Tariff (Rs/KWh) …………………………………………….………115
Figure 10.9. Commercial Tariff (Rs/ KWh) …………………………………………………115
Figure 10.10. Electricity Consumed by Sectors (% share) FY1995 ……………..116
Figure 10.11. Electricity Consumed by Sectors (% share) FY2021 ………………117
Figure 10.12. Peak Demand and Supply (MW) ……………………………………………117
Figure 11.1. CTBCM …………………………………………………………………………………..125
Figure 12.1. Power Sector Institutional Pro�ile ……………………….………………..133
Figure A1. Installed Capacity and Electricity Generated ………….……………..152
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LIST OF BOXES
Box 1.1. Corporate Governance ………………………………………………………………...17
Box 1.2. Vision: National Electricity Policy 2021 ………………………………………24
Box 2.1. Chronology of Electricity Distribution Affairs ……………………………...29
Box 2.2. Getting Electricity Connection …………………………………………………….38
Box 4.1. K-Electric (KE) Privatization ……………………………………………………….53
Box 4.2. Case of North Delhi Power Ltd. (NDPL) ……………………………………….56
Box 5.1. GENCOs Journey (1958 to 2022) …………………………………………………61
Box 5.2. Solar Power Parks: A Case of Quaid-e Azam Solar Power Park..........63
Box 6.1. Hub Power Plant …………………………………………………………………………65
Box 6.2. Power Sector Inquiry Report 2020 Findings & Aftereffects ...............71
Box 6.3. IPPs Agreement with the Government ………………………………………...71
Box 7.1. Transmission Constraints …………………………………………………………...79
Box 7.2. SCADA ………………………………………………………………………………………...81
Box 7.3. CTBCM and SCADA System ………………………………………………………….82
Box 8.1. Global Asset Management System ……………………………………………….92
Box 9.1. Planning Process Fundamentals ………………………………………………….98
Box 9.2. Power Sector Expansion Plans …………………………………………………….99
Box 9.3. Grid Code 2005 …………………………………………………………………………...99
Box 9.4. Failures of Last Three Decades ………………………………………………....100
Box 10.1. NEPRA Major Regulatory Obligations under
NEPRA Act No. XL 1997……………….............................................................104
Box 10.2. NEPRA Performance ………………………………………………………………...107
Box 10.3. Power Sector Subsidies …………………………………………………………….114
Box 10.4. History of Energy Crisis in Pakistan ………………………………………….118
Box 10.5. Linear (Flat) Tariff and Different across DISCOs ………………………..121
Box 11.1. California Electricity Market Crisis: 2000 …………………………………….128
Box 12.1. 18th Constitutional Amendment and Electricity ………………………..136
Box 12.2. Conventional Vs Smart Pre-paid Meters …………………………………….138
Box 12.3. Challenges of Pre-paid Smart Metering System in Pakistan …….....139
Box 12.4. Net Hydel Pro�its (NHP) Controversy in Pakistan ……………………….142
Box 12.5. Micro & Smart Grid vs National Grid ………………………………………….144
vi
Box A1. WAPDA's Primary Responsibilities before Power
Sector Restructuring ………….…...................................................................151
Box A2. Revenue Generation Task Force (RGTF) Report ...................................166
LIST OF TABLES
Table 1.1. Total Government Guarantees Stock_ Power Sector ……………………….4

Table 1.2. Governance Pro�ile of State-Owned DISCOs …………………………………19
Table 1.3. Financial Position of State-owned Companies ……………………………..20
Table 1.4. Cost of Electricity: Regional Comparison …………………………………….22
Table 2.1. Electricity Distribution Reliability ………………………………………………35
Table 5.1. Losses in GENCOs, 2010 ……………………………………………………………..58
Table 5.2. Capacity Installed and Generated ………………………………………………..59
Table 5.3. GENCO’s Ef�iciency and Utilization ……………………………………………...60
Table 6.1. Power Policies and Impact on IPPs ……………………………………………...69
Table 7.1. Transmission Infrastructure Owns and Maintains by NTDC …….......77
Table 7.2. Major Power Breakdowns in FY 2018 to FY 2021…………………………85
Table 8.1. Power Procurement Challenges …………………………………………………..89
Table 8.2. Reasons behind Weak Asset Management …………………………………...93
Table 9.1. Factors Affecting Power System Planning …………………………………101
Table A1. Matrix of Job Advertisements ………………………………………………...……160
vii
LIST OF ACRONYMS
ADB Asian Development Bank

AEBs Area Electricity Boards
AEDB Alternate Energy Development Board
AGC Automatic Generation Control
AGP Auditor General of Pakistan
AI Arti�icial Intelligence
AJK Azad Jammu & Kashmir
AMI Advanced Metering Infrastructure
ARE Alternate and Renewable Energy
AT&C Aggregate Technical and Commercial
B2B Business-to-Business
BODs Board of Directors
BOO Built Own Operate
BOOT Built Own Operate Transfer
BPCs Bulk Power Consumers
CBA Collective Bargaining Agreement
CCGT Combined Cycle Gas Turbine
CCPPs Combined Cycle Power Plants
CD Circular Debt
CDWP Central Development Working Party
CEO Central Executive Of�icer
CFPPs Coal Fired Power Plants
CPEC China Pakistan Economic Corridor
CPGCL Central Power Generation Company Limited
CPP Capacity Purchase Price
CPPA-G Central Power Purchasing Agency
CSD Customer Service Director
viii
CTBCM Competitive Trading Bilateral Contract Market
CTOs Chief Technology Of�icers
DBT Decreasing Block Tariff
DC Direct Current
DG Distributed Generation
DISCO Distribution Company (Public Sector)
EMS Energy Management System
EPP Energy Purchase Price
FATA Federally Administered Tribal Area
FBC Fluidized Bed Combustion
FCOs Field Circle Of�ices
FESCO Faisalabad Electric Supply Company
FSC Fuel Supply Contract
GENCO Public Sector Generation Company
GEPCO Gujranwala Electric Power Company
GHCL Generation Holding Company Limited
GIS Geographical Information System
GOP Government of Pakistan
GPP Government Power Plants
GWh Gigawatt hours
HESCO Hyderabad Electric Supply Company
HQs Headquarters
HRD Human resource Development
HRM Human Resource Management
HT High Tension
HUBCO Hub Power Company Limited
IESCO Islamabad Electric Supply Company
IFIs International Financial Institutions
IGCEP Integrated Generation Capacity Expansion Plan
IPPAC Independent Power Plants Association
ix
IPPs Independent Power Plants
IT Information Technologies
KAPCO Kot Addu Power Company Limited
KE K-Electric
KPK Khyber Pakhtunkhwa
KWh Kilowatt hours
LDC Load Dispatch Center
LESCO Lahore Electric Supply Company
LOI Letter of Intent
LT Low Tension
MD Managing Director
MO Market Operator
MEPCO Multan Electric Power Company
MLDA Multilateral Donor Agency
MOU Memorandum of Understanding
MP&M Material Procurement and Management
MVA Mega Volt Amp
MW Megawatt
NEPRA National Electric Power Regulatory Authority
NPCC National Power Control Center
NPMV Non-Project Missed Volume
NTDC National Transmission and Dispatch Company
O&M Operation & Maintenance
OEMs Original Equipment Manufacturers
OFGW Optic Fiber Ground Wire
PAR Power Acquisition Request
P&D Planning and Development
PC Planning Commission
PD Power Division
PD-MoE Power Division, Ministry of Energy
x
PEDO Pakhtunkhwa Energy Development Organization
PEPCO Pakistan Electric Power Company
PESCO Peshawar Electric Supply Company
PHPL Power Holding Private Limited
PLC Power Line Carrier Communication System
PMDC Pakistan Mineral Development Corporation
PMOs Project Management Operations
POE Panel of Experts
PP&MC Power Planning and Monitoring Company
PPA Power Purchase Agreement
PPDB Punjab Power Development Board
PPIB Private Power and Infrastructure Board
PPRA Public Procurement Regulatory Authority
PSCEs Power Sector Corporatized Entities
PSDP Public Sector Development Program
PSO Pakistan State Oil
QASPP Quaid-e Azam Solar Power Park
QESCO Quetta Electric Supply Company
R&D Research and Development
RCC Regional Control Centre
RFO Re�ined Furnace Oil
RLNG Regassi�ied Lique�ied Natural Gas
RTUs Remote Terminal Units
SBP State Bank of Pakistan
SCADA Supervisory Control and Data Acquisition
SDGs Sustainable Development Goals
SECP Security and Exchange Commission of Pakistan
SEPCO Sukkur Electric Power Company
SO System Operator
SOPs Standard Operating Procedures
xi
SSGC Sui Sothern Gas Company
SVC Static Var Compensator
T&D Transmission and Distribution
TDCs Tariff Differential Claims
TESCO Tribal Electric Supply Company
TOU Time of Use
TSEP Transmission System Expansion Plan
UHV Ultra-High Voltage
USAID United States Agency for International Development
WAPDA Water and Power Development Authority
WB World Bank
WPP Wind Power Plants
xii
PREFACE
Pakistan's energy sector has been in crisis for years. Supply shortages persist while
losses increase continuously. Too many players in the system confuse each other to
cumulate losses and give subsidies while, at the same, the circular debt is rising
continually. The government is borrowing from commercial banks to �inance the
sector de�icit. The demand-supply gap has evolved over the years from de�icits to
excess installed capacity, but there is a shortage of cash �lows and supporting
infrastructure to run it. The result is load shedding. Surprisingly, no government has
taken it seriously, saying decisions are too dif�icult. No serious research has gone into
understanding the issues. No white paper has ever been prepared.
Mismanagement/ weak governance is at every stage in the supply chain. Our decision-
makers' lack of informed long-term vision has led to distribution side inef�iciencies,
expensive fuel mix, and rising capacity payments. The results are unreliable electricity
supplies, unaffordable electricity, and increasing business costs. There is no well-
thought-out integrated energy plan.
The government's only plan to tackle the long-standing �inancial issue is to increase
consumer-end tariffs. An increase in tariffs, in the presence of so many inef�iciencies
in the system, further adds to the power sector de�icit; circular debt. Besides, an
increase in consumer-end tariffs is further burdening compliant consumers.
Policymakers are taking decisions randomly or on the advice of international �inancial

institutions; who don't understand the local dynamics of the problem. There is a
limited understanding of the value and operational electricity chain problems. There
is a lack of a holistic power sector approach. For instance, the Competitive Trading
Bilateral Contract Market (CTBCM) prepared by an international consultant is
approved to be implemented without realizing that market development is complex
and must meet speci�ic prerequisites. The reason is the shortage of in-depth policy
research covering all power sector units.
Under the guidance of Dr Nadeem Ul Haque, PIDE prepared a detailed power sector
study to �ill the research gap. PIDE formed a ‘PIDE Power Commission’ comprising
xiii
experts from the power sector carrying decades of policy and operational experience.
This in-depth research on the power sector, with the hard work of experts in the
Commission, with rich and deep insights on various segments of the power sector,
has come up with a workable, sustainable, and integrated solution to power sector
woes.
The book highlights premier challenges in the power supply chain, including generation,
transmission, distribution, regulations, tariffs, power sector/project planning, asset
management and control, competitive market, and independent power plants (IPPs).
While going through the comprehensive overview of the power sector, the book has
proposed immediate, medium, and long-term policy interventions.
It is hoped that the decision-makers will consult this book and actionable suggestions
presented in it while taking policy decisions to make the sector �inancially viable.
PIDE POWER COMMISSION
Objective:
A �inancially viable power sector with supply reliability, competitive & affordable tariffs, relying on
indigenous and green energy resources, with access to electricity for all.
Commission Members
▪ Engr TAHIR BASHARAT CHEEMA (Former MD, PEPCO) – Team Lead

▪ Engr SALIS USMAN (General Manager, Power Planning, NTDC)
▪ Engr MUJAHID ISLAM BILLAH (Ex. CEO, FESCO)
▪ Mr BASHARAT ALI (CFO, PEPCO)
▪ Engr SAJAD HAIDER SYED (Deputy Manager, NTDC)
▪ Engr MASOOD AKHTAR (Former GM, NPCC)
▪ Engr AZHAR IQBAL (Director Finance, PEPCO)
xiv
▪ Engr ADNAN RIAZ MIR (General Manager, Monitoring, PP&MC)
▪ Engr ABDUL QADEER KHAN (Ex General Manager, NPCC)
PIDE Secretariat
▪ Dr NADEEM UL HAQUE (Vice Chancellor, PIDE)

▪ Ms AFIA MALIK (Senior Research Economist, PIDE)
xv
EXECUTIVE SUMMARY
PIDE Power Commission, led by Engr Tahir Basharat Cheema, is the most knowledgeable energy
team ever assembled in the energy sector. The team has assiduously researched the entire power
supply chain, including generation, transmission, distribution, regulations, tariffs, power sector/
project planning, competitive market, and private power projects. The book has gone into power
sector history and every power supply chain segment to �ind the current crisis's root.
The book is organized into twelve chapters. The �irst chapter discusses the premier challenges
faced by the power sector. Chapter Two compares the operational and commercial ef�iciency
across distribution companies. This chapter primarily re�lects on the reasons behind the de�icient
performance of distribution companies. Chapter Three highlights that it is impossible to deal with
distribution challenges without considering some external factors linked with distribution
companies' performance. Chapter Four elaborates on the challenge of privatizing the monopolized
utility.
Chapter Five highlights the evolution of the generation side of the electricity supply chain. It
explains how and when things got worse in terms of ownership, quality, and fuel mix. Chapter Six
explains the advent of IPPs in the Pakistan Electricity System. What was wrong with the policies,
and how these adversely affected the future landscape of the power sector.
Chapter Seven discusses the load dispatch systems, challenges, and causes of power breakdowns/
blackouts in the NTDC system and why the system faced delays in restoration. Chapter Eight
deliberates power procurement challenges and hurdles. The chapter also re�lects on weaknesses
in asset management and the reasons behind them. Chapter Nine is about power system planning.
The chapter re�lects on the planning failures of the last three decades, the role of NTDC in power
planning and factors affecting planning processes and practices. The chapter traced history to
connect distribution performance with distribution system planning.
Chapter Ten is about regulatory affairs and consumer-end tariffs. It reviews NEPRA performance,
the tariff determination process, tariff anomalies and the current tariff structure. Chapter Eleven
delves into the forthcoming Competitive Trading Bilateral Contract Model (CTBCM) and �inds that
establishing a power exchange market in Pakistan in the current scenario seems impracticable.
The focus should be on bilateral contracts.
xvi
The �inal chapter provides a future architecture for the power sector in Pakistan. This chapter
details the revenue recovery plan, managerial reforms, and the signi�icance of technology and
renewable energy sources.
The main recommendations include:
Distribution
▪ Decentralize power for better management; make companies accountable for their
decisions.
▪ Split large DISCOs to prevent large natural monopolies from using market power for
advantages. Smaller units can be administered more effectively.
▪ The strengthening of human resources at all levels through independent professional
management and Human Resource Management (HRM).
▪ Mandate listing of the DISCOs in the stock exchange with a limit of 5% maximum by
one shareholder; let the institutional investors come in and manage the business.
▪ An independent/apolitical board with suf�icient capabilities to develop a business model.
Board members should be chosen, bearing in mind the con�lict of interest of industrialists
who demand bene�its from companies.
▪ Upgrade distribution infrastructure at the earliest (max 3-5 year depending on
speci�ic up-grade modules). DISCOs must be mandated to do that with matching funds
from PSDP and their resources.
▪ Only an affordable tariff in different geographical parts of the country can enable
effective revenue collection and improvement of �inancial health for investment in
infrastructure up-gradation.
▪ Decentralize the electricity billing system at the DISCO level. The ultimate solution is
the pre-paid smart metering system linked to the DISCO billing system.
▪ The future strategy for each state-owned company needs to be thoroughly grounded
in its service area's political, economic, social, environmental, and urban governance
realities.
▪ Outright privatization is not feasible, only a time-bound management contract of
selected areas.
xvii
▪ One thing is clear: the DISCOs could not be improved until unprofessional
bureaucracy is involved in its affairs.
Generation
▪ Forensic audit of both public and private generation companies immediately,

followed by recoveries without any relaxation from IPPs.
▪ There should be no conditionalities for the IPPs in the pipeline.
▪ In future, no sovereign guarantees; all investments must be based on competition
and the �inancial dynamics of the sector. A competitive bidding document must
be in place before commissioning future projects.
▪ In the short term, a moratorium on IPPs, including the proposed solar projects
of 10,000MW.
▪ So many parallel sector entities with limited capacity cannot safeguard the
people's interests needs to reduce the number & strengthen the remaining.
Power Control & Allied Issues
▪ Comprehensive grid studies for steady-state and transient stability and

reliability, considering the renewables and future energy plans up to 2040,
are critical.
▪ The priority in cost allocation for capacity building and training concerned
staff is a must.
Asset Management and Procurement in Power Sector
▪ Ensure proper coordination between the functional departments

▪ Deputation of dedicated project managers and improved project management
practices is necessary.
▪ Developing PMOs and SOPs, etc., can be the starting point toward the reform
process.
xviii
▪ There is a need to have a set of coordinated activities that improve the
performance and quality of the electricity grid.
▪ Major equipment replacement work, extension requirements, and rehabilitation
works need to be reviewed and prioritized based on power system planning
studies, substation and transmission line constraints and system stability.
▪ Intelligent Power Network Stability systems with vital telecommunication media
should replace the under/over frequency schemes..
▪ For a well-developed asset management framework, understand and include
available techniques in the strategic planning of the power industry.
▪ A progressive development, i.e., continuously evolving processes, is required
to develop the asset management system..
Power System Planning
▪ Fragmentation in power planning must change and go over to the Planning

Commission (PC).
▪ It is time that NTDC and DISCOs build their professional and institutional
capacity, launch formal R&D components in their organization, and encourage
their professionals to proactively contribute to the PC's planning process.
▪ Policymakers/planners should understand the complex economic, political, water,
and environmental interrelations and energy systems' uncertainties.
▪ Coordination in the planning process at the PC should not be limited to the
energy sector but serious consultation with other sectors.
Regulation & Consumer-end Tariffs
▪ NEPRA must be empowered to play its role as speci�ied in Clause 31 of the

NEPRA Act. NEPRA should eliminate all kinds of subsidies and cross-subsidies
from the tariff
▪ NEPRA needs to simplify its rules and processes to minimize delays.
▪ NEPRA needs to build its capacity to work and cope with sector challenges and
market forces while meeting its obligations as a regulator.
xix
▪ For recovery of capacity payments, there is a need to increase sales/ consumption
by reducing prices signi�icantly.
▪ Transitioning from a de�icit regime to a surplus one requires changing the
load separation model for power tariffs.
▪ Tariff structure should be based on economic ef�iciency, cost recovery, simplicity,
transparency, and non-discrimination.
▪ A linear (�lat) tariff rate is the best way to maximize revenues and minimize
inef�iciencies in the sector.
▪ Notify differential tariffs for each geographical market (DISCO), that is, tariff
determination based on service cost.
▪ All the socio-economic and political obligations of the government must be duly
budgeted and not part of consumer tariffs to burden compliant consumers. We
already have a social protection system. There is no need to subsidize electricity.
Electricity Market: CTBCM
▪ The market should start with bilateral contracts keeping transmission constraints
and participants' capacities in mind. When demand and supply balance and the
market attain more maturity, establish an electricity trading platform.
▪ All DISCOs should also be allowed to purchase energy on a short-term contract
and acquire generation assets falling inside their territorial jurisdictions and
outside.
▪ NEPRA should facilitate 'wheeling' by discouraging those creating hurdles, with
wheeling costs equivalent to MC.
▪ Negotiate PPAs with IPPs to free at least 50% of their capacity to be traded
in the market.
▪ The electricity market requires legal, regulatory, �inancial, and human capacity
at every level - build the capacity �irst.
.
xx
Future Architecture of the Power Sector
▪ Reduce the government footprint and ultimately move the government out of
the power sector by 2030.
▪ HRD and HRM are compulsory for a successful entity. Upgrade the training
institute(s) of WAPDA considering the present-day requirements.
▪ Shut down entities with similar functions. Shutting or merging twenty-plus
free �loat entities operating now into a single National Energy Authority could
bring about sanity and coordination in the energy sector.
▪ We need a power policy considering federation challenges, a national goal
and subsequent planning and implementation strategies.
▪ The power companies need to rely more on IT services; adopt innovative
managerial techniques. They must undertake technological changes at the
earliest.
▪ There is a need to optimize the generation portfolio. There is a need to monitor,
forecast, and manage a complex mix of small to large generation units.
▪ Due to the highly volatile global energy market, distributed generation using
localized renewable energy sources is the ultimate solution for energy security.
▪ Move from centralized energy management to decentralized management;
storage technologies; micro & smart grids.
▪ Energy conservation and ef�iciency in use should be the priority.
▪ A Power Commission comprised of hardcore power sector professionals should
be formed to guide and monitor the reform process.
xxi
Power Sector
PAKISTAN POWER SECTOR (JUNE 30, 2021)
Circular Debt Rs 2.25 trillion (June 30, 2022)

Cumulative Losses Rs 5.7 trillion (since FY2007)
Cumulative Subsidies Rs 3.4 trillion (since FY2007)
IPPs
Mini Grid & Off-Grid
Hydro 1,192 MW
Thermal 19,538 MW
Distribution
& Consumers
WAPDA Generation
Hydro 9,443 MW
GENCOs
4,731 MW CPPA-G
Receivable Rs 1.68 trillion

Payable Rs 1.45 trillion
Nuclear
3,620 MW
Renewables
2,837 MW
DISCOs 10
No. of Cons. 33.2
Imports from Iran million Energy Sold
116,902 GWh
< 1MW
K-Electric
Gen +Trans + Dist. Bulk
NTDC
No. of Cons. 3.4 Consumers
500kV grids 7200MVA; 8,388 KM million Energy Sold
220kV grids 28,160MVA; 11,611 KM 16,763.22 GWh
Central Dispatch Transmission

640 M
Supply Payment
1
Power Sector
PREMIER POWER SECTOR CHALLENGES
Financial Unviability
L
Pl ack
an of
ni Co
ng o
& rdi ply
Pr na up
oc te le S
es d re liab
s Un
PREMIER POWER
SECTOR
CHALLENGES Unaffo
rd
Expensive Fuel
Mix Uncom able &
petitiv
Tariffs e
age e &
No
nt
an anc
me
Co
mp
sm rn
Mi Gove
reh
en
of
siv
ck
eP
La
oli
cy
2
Power Sector
1. POWER SECTOR: PREMIER CHALLENGES
The power sector in Pakistan is facing several challenges for years and it continues.
1.1. FINANCIAL VIABILITY AND POWER SECTOR LOSSES
Figure 1.1. Circular Debt Growth (Rs Billion)
PTI
908
930 800
PML-N 1004
PPP
785
578
Military 216
432 1511 1453
216 1350
335 335 1043 1146
105 872 828
239 239
105 538 560
105 366 314 321
145 161 236 211 250
111
21
06
07
08
09
10
11
15
12
13
14
16
17
18
19
20
21
22
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
t.
Oc
Gross payable Amount swapped (PHPL)
Source: Malik (2020a) and NEPRA State of Industry Reports (2020, 2021, 2022)
3
Power Sector
▪ Circular debt (CD), a power sector de�icit that originated in FY2006, is continuing,
reaching Rs 2.25 trillion at the end of June 2022 (3.4% of GDP) with no respite
in sight1. The sector’s cumulative losses since FY2006 are around Rs 5.7 trillion
(including liquidity injections), equivalent to 9% of the current GDP.
▪ Since FY2007, cumulative budgetary support has crossed Rs 3.4 trillion, which
could have been used on other productive activities
▪ Government borrowed from commercial banks to �inance the power sector
de�icit, crowding out private borrowing. The stock of government guarantees
is increasing non-stop.
Table 1.1. Total Government Guarantees Stock: Power Stock
Total Govt. Guarantees Stock (Rs. Billion)
Jun -19 1,562
Jun -20 1,961
Jun -21 1,999
Sep -21 2,055
Source: Ministry of Finance: Debt Policy Statements (Various Years)
¹ The slight reduction in CD is only after stock payments of Rs 564 billion (offsetting the debt �low of Rs 536
billion during FY2022) from the budget for servicing the PHPL debt (Rs 130 billion), repaying arrears to
independent and government power producers (IPPs and GPPs) in return for revised purchasing power
agreements (Rs 384 billion), and repaying arrears to other IPPs (Rs 50 billion).
4
Power Sector
Figure 1.2. Public Debt
40,000 90
35,000 80
30,000 70
60
25,000
Rs Billion
50
20,000
%
40
15,000
30
10,000 20
5,000 10
0 0
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
1
-2
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
ar
M
External Domestic Public Debt%GDP
Source: Ministry of Finance: Debt Policy Statements (Various Years)
▪ On paper, CD �irst broke out in FY2006 with a steep rise in international

fuel prices, which increased the generation cost, but consumer-end tariffs
remained almost frozen. FY2008 and onwards, tariffs started rising. But
circular debt kept growing.
▪ The root of this challenge can be traced back to the 1990s when long-term
and unviable contracts were made with private investors on the advice of the
World Bank (WB) without analyzing their long-term impact (details in Section
VII). The same mistake was repeated over the years, trapping the sector and
the whole economy.
▪ Additionally, underlying structural issues in the form of misgovernance,
mismanagement in the energy supply chain_ inef�iciencies in the generation
and distribution, irrational tariff structure, and weak regulatory infrastructure,
all are responsible for sector losses. They are adding to the costs of electricity
services.
5
Power Sector
● Over the years, underlying structural issues have remained untouched

● Numerically, high T&D losses of distribution companies (DISCOs), lower
recovery of the billed amount and delays in payment of subsidies all add
to the circular debt accumulation. The fact ignored intentionally or
unintentionally is that an increase in tariffs encourages theft and lowers
bill recovery.
▪ Sectoral managers/ decision-makers cannot tackle this de�icit. They rely on

donor (e.g., WB, ADB, USAID) advice, who don’t understand ground realities.
These donors and our bureaucracy are responsible for this prolonged menace.
● As a result, all efforts to curtail this de�icit through an increase in

consumer-end tariffs further increase receivables (Figure 1.3).
Figure 1.3. Receivables (Rs Billion)
1600
1400 225
169.4
1200
91.7
1000
682.9
623.6
78.4
800 541.6
60.1
600 411.4
347.3
400 306.4 354.5
282.7
232.5
185.3 38.4
200 32.6 39.5
26.9 126.8 144.9 89.7
22.2 99.3
80.8 71.1 81.8
29.4 40.4 52.9
0
FY2017 FY2018 FY2019 FY2020 FY2021
Fed Govt Prov Govt AJ&K Govt FATA Agri TB Balochistan Private KE IPPs
Source: NEPRA State of Industry Reports (Various Years)
6
Power Sector
▪ Private consumers2, agriculture tube wells3, and the Government (Federal,

Provincial & AJK)4 and its departments are the major defaulters.
▪ The �inancial impact of running defaulters is around Rs. 700 million. These
consumers are still connected with the system; the respective DISCOs have
taken no action to recover their defaulted payments.
1.2. SUPPLY RELIABILITY
▪ Despite the tall claims of an increase in generation capacity, the power sector
is in de�icit after remaining in surplus for only a year in FY2020. Under the
presumption of energy ef�iciency, NTDC has forecasted a decline in peak
demand in FY2022, a weaker upward trend after that and a surplus of 9176MW
by FY2026 (Figure 1.4).
▪ We have the installed capacity but not generating enough to meet peak
demand (Figure 1.6).
2 The growth in receivables from private consumers can be attributed, in part, to electricity theft but mainly
to the point that private consumers are reaching an elasticity point whereby they are more willing to delay
because of recent signi�icant tariff increases and extra surcharges imposed (Malik, 2020). Evidence also
suggests their dissatisfaction with service delivery (Malik and Khawaja, 2021).
3 In FY 2021, 73% of the electricity procured by QESCO is consumed by agriculture consumers for running
tube wells. As per the subsidy policy (from 2001 to 2010), agriculture consumers had to pay Rs 4,000 per
month; the remaining amount was to be paid by QESCO, the Baluchistan government and the Federal
government in a ratio of 30:30:40, respectively. The subsidy program ceased in 2010 but was restored in
December 2012 without any clari�ication regarding the distribution of outstanding dues across the respective
7
Power Sector
Figure 1.4. NTDC Peak Demand and Generation Capability (MW)
40,000
35,000
30,000
25,000
20,000
15,000
10,000
5,000
0
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Supply Peak Demand
Source: NTDC Electricity Marketing Data (2022) & NEPRA State of Industry Reports (2021)
entities. In this period of 27 months, consumers were reluctant to pay their share of electricity bills beyond
Rs 4000, therefore defaulted on their bills for these 27 months. This outstanding amount (Rs 55.3 billion)
affects subsequent billing. So even if these consumers desire to clear their current period liabilities, they
cannot do so without clearing the accumulated backlog (SBP, 2019).
4 Price increase since 2015 exempts FATA and AJK via subsidies. For instance, the government subsidizes
WAPDA for receivables from AJK. But it is insuf�icient as the government in AJK does not accept NEPRA
determining tariffs and allows a tariff of only Rs 2.59 per KWh (agreed at the time of Mangla Dam Construction).
The difference adds to the receivables. In FY2021, the government paid a chunk of these arrears, reducing
receivables from AJK and FATA.
8
Power Sector
Figure 1.5. KE Peak Demand and Generation Capability (MW)

6,000
5,000
4,000
3,000
2,000
1,000
0
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Supply Peak Demand
Figure 1.6. Installed Capacity, Maximum Generation Capability and Peak Demand (MW)
45,000
40,000
35,000
30,000
25,000
20,000
15,000
10,000
5,000
0
2005 2012 2016 2020 2021
Installed Capacity Generation Capability Peak Demand
9
Power Sector
▪ Reliance on imported fuels and �iscal challenges often lead to shortages in

(generation) supplies, resulting in power outages5.
Beyond that,
▪ Power outages are an issue due to commercial loadshedding in several

parts of the country_ several clusters in KPK, Sindh and Baluchistan. In
FY2020, commercial load shedding remained in practice despite having
surplus capacity6.
▪ Excluding commercial load shedding in forecasting future demand re�lects
a lack of commitment toward identifying troubled spots and bringing
them under the complaint consumer’s net.
▪ Apart from assuming future energy ef�iciency, excluding under-met demand
due to commercial load shedding is also not considered in forecasted peak
demand (Malik and Ahmad, 2022).
5 Reference is to power outages of 8 to 10 hours in April-May 2022; imported fuel shortage and technical
reasons are cited as responsible for the shutdown of power plants. In power sector dominated by ‘Take or
Pay’ based thermal power plants and ‘Must Run’ renewable plants, underutilization/non-utilization of
available generation capacity apart from power outages, impacts the per unit cost of generation and consumer
-end tariff. In FY 2022, RLNG plants despite being the most ef�icient ones could not be operated up to their
maximum available capacity due to RLNG shortage. Besides, some of the RFO and coal power plants could
not maintain the desired fuel inventory due to non-payments by CPPA-G. Similarly, due to system (transmission
and distribution) constraints, renewable plants were unable to dispatch electricity.
⁶ Also known as revenue-based load shedding.
10
Power Sector
Figure 1.7. Average Loadshedding
1.94
KE 2.73
QESCO 8
6
SEPCO 7.3
2.33
HESCO 6
5.67
MEPCO 0.66
0.32
0
FESCO 0
LESCO 3
3
GEPCO 0.33
0
IESCO 1
1.83
1.8
PESCO 2.92
FY2021 FY2020
Source: NEPRA Distribution Companies Performance Report (2021)

Note: The data submitted by PESCO is different from ground realities (NEPRA, 2021).
▪ Distribution companies (state-owned) or privatized KE are responsible for

providing an uninterrupted supply of available electricity to consumers in their
territories.
▪ The Daily Log Reports of System Operator (NTDC) show load management/
load-shedding of around 2,500 MW to 3,000 MW during FY 2020-21. Similarly,
KE also continued to carry out load-shedding in its service territory (NEPRA
State of Industry Report, 2021).
▪ The Power Policy of 20137 explicitly allowed load shedding in loss-making
areas. KE adopted this strategy for the �irst time. Now, other DISCOs are
following. Although in the new Power Policy 2021, there is no explicit provision
for this policy. But the practice continues.
● This strategy should have been adopted only for a short period. During
which non-compliant consumers are mainstreamed or forced to pay for
the electricity they use. This has not been done over the last nine years.
⁷ Section 7.8, page 17, Power Policy 2013.
11
Power Sector
▪ No audit by the regulator, i.e., NEPRA; why does this commercial load shedding
continues for so long?
▪ Commercial load shedding has reduced demand and compatible less use of
available generation capacity, in�lation of capacity charges and its likely impact
on increasing tariffs for compliant consumers.
In addition,
▪ It skewed planning for new power generation, transmission, and distribution

infrastructure; and compromised future assessments. Thus, negatively
in�luencing investor interests.
▪ The practice of load shedding is creating discontent among the three small
provinces (KPK, Sindh and Baluchistan), affecting the federation.
On the other hand,
▪ There is a stark difference in electricity usage between day and night. Likewise,
seasonal variation in electricity usage is high in Pakistan. Summers and winters
differ in peak demands of anything between 8,000 to 13,000MWs. TOU tariffs
variation is not enough to cater to this enormous demand difference.
▪ For instance, in FY 2022, 28,253 MW was the peak demand in June 2022 while
during December 2021 the peak demand came down to 15,962 MW. On the
other hand, the installed capacity with ‘Take or Pay’ and must run power plants
was 40,813 MW. Higher installed capacity as compared to demand in the system
burdens the power sector adversely. Therefore, the gap between the ‘Take or
Pay’ available power generation capacity and demand in the system needs to
be as minimum as possible.
1.3. UNAFFORDABLE & UNCOMPETITIVE TARIFFS
▪ A massive increase in consumer-end tariffs in the last few years (Figure 1.8) _
a percentage increase in average sale price was about 51% between FY2017
and FY2021.
12
Power Sector
▪ Electricity tariff in Pakistan is around 30% to 40% higher than in countries

like India, Malaysia, Turkey, and China (Sattar and Umar, 2020).
▪ The government is under pressure to reduce electricity subsidies (IMF
condition) and increase consumer tariffs.
▪ Several surcharges to �inance banks and other government liabilities further
increase consumer tariffs.
▪ Due to existing anomalies in the subsidy structure, not only are consumer-
end tariffs shooting up, but government subsidies are also rising (Figure 1.9).
Thus, increasing not only the consumer burden but �iscal burden.
Figure 1.8. Average Sale Price (Rs/KWh)
25.00
20.00
15.00
10.00
5.00
0.00
1985-86
1989-90
1990-91
1991-92
1992-93
1993-94
1994-95
1995-96
1996-97
1997-98
1998-99
1999-00
2000-01
2001-02
2002-03
2003-04
2004-05
2005-06
2006-07
2007-08
2008-09
2009-10
2010-11
2011-12
2012-13
2013-14
2014-15
2015-16
2016-17
FY2018
FY2019
FY2020
FY2021
DISCOs KEL
Source: NTDC Electricity Marketing Data (2022) & NEPRA State of Industry Report (Various Years)
13
Power Sector
Figure 1.9. Power Sector Subsidies (Rs Billion)
500
450
400
350
300
250
200
150
100
50
0
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
Inter-DISCO Tariff Differential FATA Agri. Tubewells Industry Others
Source: Ministry of Finance: Budget in Brief (2008 to 2022)
▪ Cross-subsidization across sectors is affecting industrial competitiveness

(Figure 1.10). However, special tariff dispensation has been allowed to the
zero-rated industry through a budgeted subsidy since FY2018, which is not
sustainable given government �iscal constraints. Details on tariff structure in
Pakistan are in Chapter 10.
14
Power Sector
Figure 1.10. Average Sale Price (Rs/KWh)
35
Commercial, 30.7
30
25
Industry, 21.6
20
Domestic, 14.6
15
10
Agriculture, 13.4
0
91
02
07
08
10
12
14
15
16
17
18
19
20
21
19
20
20
20
20
20
20
20
20
20
20
20
20
20
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
FY
Source: Authors’ Estimations
15
Power Sector
1.4. GOVERNANCE
Figure 1.11. Power Sector Governance Structure
Government
of Pakistan
Ministry of Energy
(Power Division)
PPIB AEDB CPPA-G WAPDA GHCL NTDC PEPCO/ NEECA NESPAK

PPMC
Independent Renewable Hydro

Power Plants Private Projects Projects DISCOs PITC
GENCOs
▪ Presently, the power sector governance lies with the Power Division (PD) in
the Ministry of Energy (MoE).
▪ National Transmission and Dispatch Company (NTDC), the ten state-owned
distribution companies (DISCOs) and the four state-owned generation companies
(GENCOs) are all under the direct control of the Secretary, Joint or Deputy
Secretaries of the Power Division.
▪ The GENCOs (four in number) with an installed capacity of 4881 MW are
managed by the GENCO Holding Company Ltd. (GHCL); GHCL is not accountable
to anyone.
▪ There is no effective coordination between the power sector's generation,
transmission, and distribution facets8.
8 Under WAPDA, the sector used to have cohesive management and the availability of over 9,000 engineers
and other professionals for assistance and support.
16
Power Sector
▪ With the vague job description of the Federal Secretary, frequent changes in
the personality have been witnessed in recent years
▪ In the absence of required technical expertise, the PD is left to discuss losses
and recovery issues super�icially while ignoring other vital aspects9 .
▪ Consequently, nothing has changed; neither losses have reduced, nor has
recovery improved. Receivables are going up, and CD is increasing non-stop.
▪ The reform process started in the late 1990s and, after three decades, is in a
deadlock.
▪ CEOs in state-owned companies change frequently; professionals are not
considered for these posts.
▪ Despite being corporatized, it is not clear under which law these companies
are governed.
▪ Over the years, the sector's government footprint (power division) has become
even more robust than decentralizing power.
1.5. CORPORATE GOVERNANCE AND MANAGEMENT
▪ The management of NTDC, GENCOs, Box 1.1. Corporate Governance

and DISCOs is two-tiered, i.e., CEOs and
▪ Corporate governance de�ines the
BODs. rights and responsibilities of a
board, managers, shareholders, and
▪ According to SECP Public Sector Companies
other stakeholders. It outlines
(Corporate Governance) Rules, 2013, it decision-making rules & procedures
is mandatory for each company to have (Haque and Hussain, 2021).
independent directors_ 40% of its total ▪ Corporate governance of the utility_

members. private or state-owned is crucial for
effective operations. Its mechanisms,
▪ On paper, every DISCO has independent such as monitoring, board of
directors and executive plans, are
board members with limited authority signi�icant (Cited from Malik, 2021).
to make decisions.
These companies (GENCOS, NTDC, and DISCOs) are under complete government control; board
and management positions at DISCOs are held by government employees or political appointees
with limited experience. Of�icials sitting on multiple energy boards aggravate this issue.
9 Relying on donor reports and advisory.
17
Power Sector
▪ Board members in these companies comprise non-sectoral professionals. Even

if some professional is appointed, is not allowed to stay for long.
▪ Not only are boards incompetent, but they also have no clear objectives
or guidelines and no power to take critical decisions.
▪ CEOs only have acting charge and not permanent of�ice holders, appointed on
a seniority basis, and not based on their managerial capacity. The authority
to appoint rests with the PD and with the boards.
▪ CEOs are kept busy in meetings, with little or no time to manage the company
(DISCOs or GENCOs).
▪ As is evident from the minutes of the board meetings10 , the meetings only
discuss human resource issues.
▪ In recent months, new boards have been appointed in all ten DISCOs. Though some
professionals were appointed, the majority remained non-professionals.
▪ Preference is given to those who remained af�iliated with KE, in various
capacities . In addition, a few from ENGRO and having linked with the AES
Corporation (which had set up the most IPPs in the country) are chosen as
board members11.
▪ Consultants are given preference over professionals in the selection12.
10 This information is extracted from newspaper clippings, studies, informal discussions with some DISCO
officials etc.
11 Chairman NTDC is also on the board of KE, clearly violating corporate law. NTDC and KE deal in billions
of US$ business with each other.
12 As reported in newspapers, relying on KE employees is to prepare for the future privatization of these
companies.
18
Power Sector
Table 1.2 Governance Pro�ile of State-Owned DISCOs
Independent Ex-of�icio/ Change in CEOs Shareholding

Directors * Non-executive since 2016
Directors
FESCO 5 2 4 100% Govt.
HESCO 8 3 5 100% WAPDA
QESCO 5 1 3 ** 100% WAPDA
TESCO 4 4 4 100% WAPDA
PESCO 4 4 4 100% WAPDA
LESCO 6 3 5 100% Govt
IESCO 7 3 5 88% WAPDA; 12% others
GEPCO 5 5 4 99% Govt; 1%others
MEPCO 7 2 4 100% WAPDA
SEPCO 7 NA 3 100% WAPDA
Source: Financial Footprint: SOE Annual Report (2018-19), Ministry of Finance, Government of Pakistan; and
of�icial websites of relevant companies.
* Independent directors excluding chairman and company secretary
** current information not available, different information in different source.
▪ Non-professional BOD, temporary CEOs in the last decade and non-availability

of the most necessary national power policy_ NTDC is not fully able to deliver
the needed power to the distribution companies and accept and transmit
ARE of the requisite level.
▪ Any positive change in the sector depends on a change in its governance
structure and not on the availability of power.
19
Power Sector
▪ No signi�icant change can be expected if the sector continues to be governed by

bureaucracy. If professionals are not allowed to manage, all power sector issues
will remain and grow.
▪ There will remain a shortfall in revenues against the projected energy usage,
thus adding to the existing power sector de�icit, that is, CD. This de�icit will,
turn, reduce the sector’s capacity to pay for its generation receipts. Thus,
reduced generation, load shedding, and increased capacity payments burden
requiring consumer-end tariff to increase.
Table 1.3. Financial Position of State-owned Companies
Assets Liabilities Net Pro�it
(Rs Million) (Rs Million) (Rs Million)
GENCOs (I, II, III, IV) 448,609 380,749 3,165
NTDC 401,813 244,069 11,236
DISCOs 1,983,044 2,838,875 -1,143,052
WAPDA 2,013,060 527,772 -7,724
Source: Federal Footprint: SOE Annual Report (2018-19)
1.6. LACK OF COORDINATED PLANNING
▪ Our policymakers' lack of informed long-term vision has cost Pakistan dearly
(Alahdad, 2012).
▪ The induction of IPPs has relieved some burden on the public sector. Still,
unplanned contracts have considerably increased the cost of a generation
because of ballooned capacity payments and expensive fuel mix. In FY2022,
20
Power Sector
the utilization factor of 30,303 MW thermal power plants on take-or-pay was

46%, which means that consumers had to pay capacity charges for the remaining
54% of the unutilized capacity as well (NEPRA State of Industry Report, 2022).
▪ Lack of cost-effective planning resulted in direct deals with IPPs.
▪ The absence of competitive bidding in the power procurement process and
long-term contracts have brought structural rigidity and hindrances to creating
a competitive market and prices.
▪ Consumers are forced to pay a higher (non-competitive) price for electricity.
has the highest cost of electricity in South Asia (Table 1.4).
Figure 1.12. Installed Capacity (MW)
25,000 45,000
40,000
20,000
35,000
30,000
15,000
25,000
20,000
10,000
15,000
10,000
5,000
5,000
0 0
1982 1991 2001 2006 2012 2016 2020 2021
Public Private Total
Source: NTDC Electricity Marketing Data (2022) & NEPRA State of Industry Reports (Various Years)
21
Power Sector
Table 1.4. Cost of Electricity: Regional Comparison
Cents/ KWh Residential Commercial Industry
Pakistan 1.3-15.4 12.4-15.9 11.8-12.5
India 4.2-11.2 8.4-11.9 10.9
Bangladesh 4.1-12.6 10.8 6.8
Source: Report on the Power Sector (2020)
▪ It is estimated that a per unit increase in price by Rs 1 would add to an additional

loss of more than Rs 10 billion; as it affects the paying capacity of that in turn
will increase poverty, theft and delayed or no payment, increasing arrears
(Faraz, 2018).
▪ GENCOs also suffer from a lack of planning. GENCOs are running below their
net available capacities because the desired maintenance and scheduled outages
over the years are not in place as per standard industry practices. These plants'
unproductive use of resources adds to the power sector de�icit. It also denies
the sector of relatively cheaper electricity (NEPRA State of Industry Report, 2019).
▪ Over the years, policymakers have focused on new projects rather than
maintaining the available capacity, thus hurting their fuel ef�iciency, and putting
costly electricity in the system.
▪ The top planning failure in Pakistan is the shortage of T&D networks. Investments
in generation capacity are not complemented by equivalent investment in
downstream T&D infrastructure.
▪ More than one-fourth of electricity is lost due to ruined networks, theft, and
insuf�icient energy accounting.
▪ T&D capacity is much less than the installed generation capacity. The transmission
network allows only 23,000 MW-peak, with close to 3% loss. About 10GWh of
22
Power Sector
generation cannot be evacuated due to system constraints.

▪ NTDC is the power planner. There is no integrated long-term plan. The focus
has remained on generation plans but not on an integrated plan.
▪ There is a lack of coordination among various departments in the sector. The
capacity needs to be doubled (55,000 MVA to over 100,000 MVA) by 2025 to
transmit the available generation capacity. Yet, the target is dif�icult to achieve.
▪ NTDC is further not able to provide the needed transmission lines in the northern
areas because of space constraints.
▪ There is no plan to increase electricity sales in Sindh, Baluchistan and KPK,
where many areas are still not connected to the national grid.
▪ NTDC has not been able to upgrade its transmission voltage or induct newer
technologies like UHV transmission lines, SVCs, and storage batteries to cater
for the above constraints. More details in Chapter 7 to Chapter 9.
1.7. LACK OF COMPREHENSIVE POLICY
Under WAPDA, the power sector vision was "to provide continuous, standard, affordable
power to the people of Pakistan." The vision lays down the policy, principles, and direction
(implementation strategy) for achieving sustainable, reliable, and affordable electricity
for the people of Pakistan.
▪ The Power Policies of 1994, 2002, 2007, 2015, and 2019 cater only to speci�ic
interests/subjects. Even the new Electricity Policy of 2021 is no different.
▪ All of these were/are crafted to meet the special interests of speci�ic groups,
not for the betterment of the consumers. All these policies have been successful
in their intent yet, have led to the near collapse of the sector.
▪ All policies remained oblivious to the national requirements.
23
Power Sector
Box 1.2. Vision_ National The customers wish for continuity of supply
Electricity Policy 2021 _ no load shedding, proper billing at an
affordable price, prompt provision of new
To ensure universal access to electricity connections and priority of supply complaints;
through a self-sustainable power sector none of this is happening now.
developed and premised on:
The requirements of the power sector manager
▪ Optimal utilization of indigenous
resources. (GOP), and the customers aredivergent. The
▪ Integrated planning approach. GOP wishes the power sector to operate so
▪ Ef�icient, liquid, and competitive
market design. that there is no CD and no �inancial burden
▪ Affordable & environment-friendly for the government. The National Electricity
outcomes for the consumers.
Policy 2021 cater for government demand
only.
▪ The policy envisages full recovery of the supply cost (including inef�iciencies)
from compliant consumers. It allowed cross-subsidies and uniform tariffs to
meet the GOP's socio-political objective. It belies any claim that the consumer-end
tariff would be decreased soon.
● It will increase the burden on the law-abiding consumers with no alternative

option to avoid this tariff hike.
● It will not have any positive impact on DISCO's recoveries. Under this, the
blackmailing of KE will continue, along with the suffering for consumers
in Karachi.
● There is nothing in the policy to ensure continuity in supplies, accurate
billing an affordable price, prompt provision of new connections and
priority resolution of supply complaints.
▪ The generation mix (because of all previous policies) comprises hydel, thermal
(oil-�ired, gas-�ired – including RLNG, and coal-�ired), nuclear and alternative
& renewable energy like solar, wind and bagasse power plants.
● AREs capacities are being inducted without any stringent policy framework.
The compatible built-up of transmission and distribution infrastructure
is also lacking.
24
Power Sector
● Local gas resources are depleting with no signi�icant new gas discoveries,
yet the policy is talking about utilizing local gas resources.
▪ For those with no access to electricity, there are two options: to supply electricity
to areas already connected to the grid and the rest through distributed generation
(DG) or to connect the whole country to the national grid. These areas are
mainly in the three small provinces_ Sindh, KPK and Baluchistan.
● AREs and DG are recommended for these provinces in GOP policy frameworks.
● AREs are best designed to support the national grid but cannot lead to a
sustainable autonomous system for the starved population in KPK, Sindh
and Baluchistan.
▪ Rural electri�ication has remained a goal, but no comprehensive policy guideline

is available to guide grid expansion.
● Villages get electri�ied each year, but the absence of system planning due
to the lack of comprehensive policy results in the disturbance of LT and HT
ratio, one of the root causes of technical losses and reliability issues.
▪ The power sector requires an all-inclusive power policy, catering to federation

challenges, a national goal, which is missing, and subsequently lack of
implementation strategies.
▪ Without goal-speci�ic policy direction, the sector will remain directionless.
1.8. EXPENSIVE FUEL MIX: A PLANNING FAILURE
In Pakistan, there is no market for energy. It is the government deciding about future
projects. While we also failed to develop an integrated energy plan. Due to the lack of
long-term planning, its processes, and wrong decisions by government-owned entities,
more than 40% of the generation is based on imported fuels. Any increase in international
fuel prices or devaluation of the Pakistani rupee often leads to load shedding and
worsening of the CD problem. In the 1990s, there was space to undertake long-term
policy decisions. If the generous tariffs offered to IPPs were extended to hydro plants,
our power sector would have been far better today (SBP, 2014).
25
Power Sector
Figure 1.13. Installed Generation Capacity FY2022
Gas
8%
Hydro
RFO 26%
13%
Bagasse
1%
Wind
4%
Solar
RLNG 1%
25%
Nuclear
9%
Domestic CoalImported Coal
3% 10%
Source: IGCEP (2022-31)
▪ The dynamics of the electricity supply chain have changed signi�icantly with the
exhaustion of indigenous natural gas resources.
▪ In the Generation Policy 2015, preference was given to RLNG and coal, but not
reducing dependence on imported fuels. All the new projects are increasingly
dependent on’ imported fuels.
▪ Retirement of expensive furnace oil plants was planned in the recent past but could
not be implemented because of constraints on foreign exchange reserves and rupee
devaluation. The result is an increase in the generation cost.
▪ Share of oil in our generation mix has decreased from 47% in FY1998 to only
13% in FY2022. Our dependence on another imported fuel RLNG has increased
from 0.7% in FY2015 to 25% in FY2022. Whereas, in FY2022, due to RLNG
shortage, expensive and inef�icient plants were forced to operate causing a
�inancial impact of Rs. 19,332 million13.
13 NEPRA State of Industry Report (2022)
26
Power Sector
▪ Share of coal in the electricity fuel mix has increased from 0.5% in FY2014 to
13% in FY2022.
▪ Most of the new coal-�ired power plants are fueled by imported coal, which has
become extremely expensive after the rupee devaluation.
▪ Failure to add new hydro capacity in the system over the years and continued
dependence on imported fuels resulted in an unbearable �inancial burden of
subsidies and CD.
Figure 1.14. Fuel Cost (Rs/ KWh) in CPPA-G System
30.00
25.00
20.00
15.00
10.00
5.00
0.00
Coal HSD RFO Gas RLNG Nuclear Import Iran Mixed Bagasse
FY2020 FY2021 FY2022
Source: NEPRA State of Industry Reports (2020, 2021, 2022)
27
Power Sector
Figure 1.15. Cost Invoiced by Generators Rs Billion (FY2022)
800
700
600
500
400 361 607
300
20
200 325
2 2
100 225 203 8
121 114 19 1
94 60 5 95
0
ed
rt
l
ar
ar
l
d
de
dy
ss
in
RF
HS
po
Co
l
e
ix
So
Hy
Hy
ga
cl
M
Im
s/
Nu
Ba
P
DA
a
/G
IP
AP
NG
W
RL
CPP EPP
Source: NEPRA State of Industry Report (2022)
In our planning strategies, the utilization of indigenous resources has always been at the
forefront, but unfortunately, these plans have not been timely implemented. We started
Neelum-Jhelum from Rs. 18 billion in 2008 and completed it in 2018 at the cost of Rs.
510 billion (levelized tariff of Rs. 13.5 per unit). Rs. 510 billion is more than $5 million
per MW when countries around us are doing the same at under $2 million per MW.
Wind and solar are quickly becoming the cheapest sources of generation technologies,
yet the share of wind and solar energy projects is relatively small. There is no consistency
in net-metering policy for households; solar on households has remained an uncertain
policy, sometimes taxed, and sometimes taxes are relaxed.
Renewables are increasingly competing on an economic basis in energy markets globally.

Due to the lack of energy market and comprehensive planning for the future, coal and
RLNG plants will keep Pakistan's reliance on expensive imported fuels in the coming
years. In Pakistan, geo-political factors and the urge for quick �ixes stand in the way of
improving renewables' competitiveness.
28
Power Sector
2. DISTRIBUTION CHALLENGES: WHY ARE DISCOS NOT

DELIVERING?
DISCOs have yet to grow as an institution. The bureaucracy does decision-making

on all matters; management and boards are ineffective; there is a weak
distribution infrastructure, no funds, and no innovative processes. The DISCOs
could not be improved until unprofessional bureaucracy is involved in its affairs.
Box 2.1. Chronology of Electricity Distribution Affairs
▪ In 1982, AEBs were established under WAPDA to provide more autonomy to the
power distribution operations; allowed representation of provincial governments,
elected representatives, industrialists, agriculturalists, and other interested groups on
boards
▪ In the 1990s, big industrial and commercial out�its were set up. The electricity demand
surged (growth of 9-10% consistently).
▪ Inadequate availability of capital led to a shortfall in generation capacity_ creating
a demand-supply gap.
▪ Lack of investment in the upgradation/ expansion/ maintenance led to the
deterioration of existing dated transmission and distribution infrastructure. This
aggravates power shortages and unreliability in supplies.
▪ The overall operational and commercial inef�iciencies in the power distribution
sector created the need for restructuring.
▪ In 1998, with the reorganization of WAPDA (under the Power Sector Reform Plan),
the distribution sector was restructured into eight public limited companies (DISCOs)
(which later increased to ten) under the corporate law; they were placed under the
PEPCO management.
▪ An independent BODs was appointed in each company.
▪ PEPCO centralized control over the unbundled companies' operations made boards
and management of these separated companies ineffective.
▪ Under PEPCO, newly corporatized DISCOs moved away from the earlier designs,
standards, procurement, disposal, transport, �inance, etc., developed under WAPDA
in its early days.
▪ In 2011, the GOP approved the dissolution of PEPCO, and the functions were �irst
transferred to NTDC and later to CPPA-G.
29
Power Sector
1.2. SUPPLY RELIABILITY
▪ Pakistan's power sector has long faced multifaceted and complex challenges.
▪ Several of these, including high distribution losses, unreliable electricity supply
and power outages due to a system and �inancial constraints, non-recovery of
targeted revenue and the (signi�icant portion) of mounting CD, is all because
of the below-par performance of electricity distribution companies.
▪ The electricity distribution companies _ ten state-owned (DISCOs) and a privatized
KE. (KESC – as incorporated in 1913), vary in ef�iciency and performance.
The vision of the National Electricity Policy 2021 is to ensure universal access to electricity
through a self-sustainable power sector. The policy is aimed at making the power sector
viable. It is premised on the ef�icient operations of the distribution system and timely
recoveries from consumers
2.1. DISCO’s MAJOR CHALLENGES
(i) Technical and Distribution (T&D) losses_ a fraction of electricity lost due to
technical (engineering) reasons and unmetered consumption or theft.
(ii) Low revenue recovery ratio_ a signi�icant fraction of bills unpaid by consumers.
These two major challenges are leading to subsequent issues for the distribution sector
and for the overall power sector.
Technical and Distribution (T&D) Losses: Operational Inef�iciency
▪ In FY2021, % losses were highest in PESCO region (38%), followed by SEPCO

(35.5%), HESCO (28.2%), and QESCO (28%). Except for LESCO and MEPCO,
the other three DISCOs have losses below 10% in Punjab.
It's a myth that

▪ Distribution companies in Punjab are relatively better, and privatized utility
performs better than state-owned utilities. In FY2021, MEPCO and LESCO have
the third and fourth highest T&D unit losses (in million KWh, Figure 2.2) after
30
Power Sector
PESCO and K-El.

▪ Over the years, average T&D losses have declined in percentage terms, but in terms
of KWh and subsequently in PKR, these have increased substantially (Figure 2.3).
▪ NEPRA uses T&D target as a tool to improve the operational performance of
distribution companies. However, this strategy has not worked for most DISCOs.
There is no signi�icant penalty associated with utility mismanagement, leading
to operational inef�iciency (Malik, 2022c).
Figure 2.1. T&D Losses (%) in FY2021
40
35
30
25
20
15
10
5
0
PESCO TESCO IESCO GEPCO FESCO LESCO MEPCO QESCO SEPCO HESCO K-El
Source: NEPRA State of Industry Report (2021) & NEPRA Performance Evaluation Report: DISCOs (2021)
Figure 2.2. T&D Losses in Million KWh in FY2021
7000
6000
5000
4000
3000
2000
1000
0
31
Power Sector
Figure 2.3. Transmission & Distribution Losses
30 30
25 25
20 20
Billion KWh
15 15
%
10 10
5 5
0 0
1985-86
1989-90
1990-91
1991-92
1992-93
1993-94
1994-95
1995-96
1996-97
1997-98
1998-99
1999-00
2000-01
2001-02
2002-03
2003-04
2004-05
2005-06
2006-07
2007-08
2008-09
2009-10
2010-11
2011-12
2012-13
2013-14
2014-15
2015-16
2016-17
FY2018
FY2019
FY2020
FY2021
% Billion Units (KwH)
Source: NTDC Electricity Marketing Data (2022)
Low Recovery Ratio: Commercial Inef�iciency
▪ Revenue recovery rates are relatively high for all DISCOs in Punjab but fall
signi�icantly for DISCOs in Sindh, Baluchistan and KP.
▪ More than 100% collection in PESCO, IESCO, GEPCO and MEPCO in FY2021 are
due to one-time deposit of arrears (AJK and others) by the GOP.
▪ There is wide dispersion in T&D losses and revenue recovery rates even within
each distribution company (Figure 2.6).
▪ Together, the lost electricity and unpaid bills translate into billions of rupees
of losses yearly. Despite a signi�icant improvement in bill recoveries in FY 2021,
the receivables from DISCOs increased by Rs. 120 billion from FY2020 to
FY2021, which accumulated as CD.
32
Power Sector
Figure 2.4. Percentage Recoveries in FY2021
140
120
100
80
60
40
20
0
Figure 2.5. Recovery Loss in Rs. Million (FY2021)
50000
40000
30000
20000
10000
0
-10000 PESCO TESCO IESCO GEPCO FESCO LESCO MEPCO QESCO SEPCO HESCO K-El
-20000
-30000
-40000
-50000
-60000
▪ These losses are hindering a sizable investment in the upgradation of

infrastructure. This results in unreliability of electricity supplies.
▪ None of the reform efforts in the past has been successful in improving service
delivery. Instead, the experience is of an ever-rising cost of provision and never
-ending load shedding.
33
Power Sector
Figure 2.6. Circle-wise % Recovery in PESCO (June 2021)
120
100
80
60
40
20
0
Peshawar Khyber Mardan Hazara Swat Bannu Hazara-2 Swabi
Source: PESCO Commercial Report (2021)
▪ Despite widespread theft of energy, there is a delay in the promulgation of an

electricity act (drafted some �ive years ago), tells the importance accorded to
this sensitive issue by the decisionmakers.
Lack of �inancial resources and resistance from stakeholders are hindering
▪ moving towards smart energy solutions like pre-paid smart meters.
Not only the failed writ of the state in several parts of Pakistan, including FATA,
▪ hinterlands of Baluchistan, some pockets in Sindh and Punjab, but the
undisciplined power consumers is a huge threat to possible revival of the
system.
▪ Reliable electricity distribution services primarily depend on the suitability of

three major components including 11 kV feeders, power transformers (mostly
132/11 kV transformers) and the distribution transformers.
34
Power Sector
Table 2.1. Electricity Distribution Reliability
NEPRA Target
MEPCO
HESCO
QESCO
LESCO
K-El.
GEPCO
PESCO
SEPCO
FESCO
IESCO
SAIFI No. 13 193.7 0.05 24.78 35.53 34.66 471 97.96 441.04 137.1 28
SAIDI No. 14 14821 1.36 40.33 1252.7 3821.84 39733 8176.2 3893.3 7852.2 2565
Source: NEPRA Performance Evaluation Report: DISCOs (2021)
Figure 2.7. State of Distribution Infrastructure
11KV Feeders Power Transformers Distribution Transformers
Punjab Punjab Punjab

No. 6,969 No. 1,421 No. 5,58,474
Overloaded 11.7% Overloaded 13.5% Overloaded 5.1%
Sindh Sindh Sindh

No. 1,118 No. 255 No. 82,949
Overloaded 14.3% Overloaded 13.3% Overloaded 4.6%
KP KP KP
No. 1,413 No. 307 No. 98,340
Overloaded 41% Overloaded 35.5% Overloaded 6%
Balochistan Balochistan Balochistan

No. 688 No. 179 No. 64,119
Overloaded 100% Overloaded 27.4% Overloaded 8.3%
Source: NEPRA Performance Evaluation Report: DISCOs (2021)
35
Power Sector
Safety Policy
▪ High number of fatalities (Figure 2.8) shows that DISCOs have failed to comply
with safety standards as prescribed in performance standards; re�lecting their
weak safety polices.
▪ In some DISCOs, shortage of skilled staff and work overload results in fatal
accidents.
Figure 2.8. Number of Fatal Accidents
60
54
50
43
39
40
31 32
29
30
23 22
20 16 17
141313 14
12 12 11 1213 12
8 7 8 9 9 8 8
10 7 7 6
0
PESCO IESCO GEPCO FESCO LESCO MEPCO QESCO SEPCO HESCO K-El
FY2019 FY2020 FY2021
Source: NEPRA Performance Evaluation Report: Distribution (2021)
2.2. POOR ELECTRICITY DISTRIBUTION PERFORMANCE: MAJOR REASONS
Institutional Failing
▪ Over the years, DISCOs have not grown as an institution.
▪ There is confusion about whether DISCO is a corporate business or a government

entity.
36
Power Sector
▪ The day-to-day operations are the same as in any government department.
▪ The interference of political elite or otherwise in�luential groups is common.
▪ DISCO employees /management, after corporatization, are company employees.

But they are still treated as government employees (as they used to be in
WAPDA days up to 2007). Management gets transferred quite frequently.
▪ No roadmap for HRD and towards the adaptation of smart meters, smart grid,
and CTBCM. Capacity building of staff for emerging technologies like SCADA,
AMI and GIS etc. is missing.
▪ Scarcity of quali�ied technical staff, e.g., lineman.
▪ There is a lack of commercial mindset at these DISCOs; no strategic planning

to expand pro�its. No business model in these companies.
▪ Ten state-owned DISCOS, on average, recorded a net loss of Rs 143 billion in
FY 2019. The net loss increased by 18 per cent between FY2014 and FY2019
(Figure 2.8).
Figure 2.9. Net Pro�it/Loss after Tax (Rs Million)
40000
30000
20000
10000
0
-10000 IESCO LESCO FESCO GEPCO MEPCO HESCO QESCO TESCO PESCO SEPCO
-20000
-30000
-40000
-50000
-60000
-70000
FY2014 FY2015 FY2016 FY2017 FY2018 FY2019
Source: Federal Footprint: SOE Annual Report (Various Years)
37
Power Sector
Box 2.2. Getting Electricity Connection
The consumer-centric approach is to the extent that hundreds of thousands of applications

for new connections are pending because of bureaucratic delays. File processing by the
officials at the DISCOs is a significant source of sludge in getting an electricity connection.
More than 600,000 applications are pending in the PEPCO area, while around 100,000 are
in the KE.
Time Consumed (Days) Cost (PKR)
Total Time 62 Total Cost Rs. 17,700
Agency Time 53 Stress Level Monetary Cost Rs. 13,000

3/5
Overhead Time 6 Opportunity Cost Rs. 4,700
Processing Time 3 Speed Money Rs. 10,000
Source: Haque, Faraz & Mustafa (2021)
The delays in getting electricity connection (Box 2.2) are in the presence of the enormous
capacity charges paid by the CPPA-G, which get translated into an unwarranted increase
in consumer tariff.
▪ An increase in billed demand for electricity (i.e., electricity sales) can reduce
the burden of capacity payments on consumer tariffs.
38 38
Power Sector
Action Points
▪ Facilitate a corporate culture in DISCOs with a viable business model as also

envisaged in the National Electricity Policy 2021. Each company must have a
business model based on its domestic market conditions.
▪ For increasing transparency and accountability, a well-designed website for each

DISCO.
▪ Minutes of each board meeting or at least major decisions should be publicly

available. Their annual reports, as well as �inancial statements, should be
available for public scrutiny and in time.
▪ The government should only be a policymaker. Its only job is to improve the
business environment via enforcing contracts, improving laws, and simplifying tax
administration.
▪ Professional and competitive management with a clear corporate vision and

business plans for organizing the utility on commercial lines is urgent.
▪ These professionals must have the capacity to develop a comprehensive revenue

collection and theft prevention program in their respective companies.
▪ Need for adaptability and training for emerging technologies like smart grid,
pre-paid meters.
▪ For tariff petitions, a correct load forecast is essential. It can be done by adopting
technology and building the capacity of staff.
▪ No mercy for DISCO employees involved in facilitating theft or billing de�iciencies.
▪ Decentralize power sector for better management; make companies

accountable for their decisions_ operational and �inancial.
▪ Revenue-based load shedding must stop. It leads to more problems than any
advantage for the power sector or even the federation. The non-compliant areas
must be mainstreamed under some innovative ideas.
▪ Must provide new connections within 30 days of registering the requests.
Organizational Structure
▪ After corporatization, DISCO headquarters (HQ) structures have broadened.
39
Power Sector
▪ Instead of decentralizing and empowering �ield of�ices, the HQs have taken
many duties of the FCOs. Now HQs entertain power consumers for supply and
billing issues.
▪ Over the years, the DISCOs organizational structure has been further weakened.
▪ It is starved of �ield staff, supervisory staff, tools and plants, modern equipment,
access to distribution design parameters, and transport required to check
power theft and recover bills.
▪ A DISCO organogram is more like a multi-business conglomerate than a power

distribution utility.
▪ Privatization was planned in three years; therefore, no change in �ield

formation was made—but, neither privatization nor any improvement in the
�ield structure.
Figure 2.10. Shortages at LESCO
Sub-divisional Supervisory Line Staff Meters

Of�icers Staff
50% 65% 71% 61%
Source: LESCO (Online: www.lesco.com.pk)
40
Power Sector
Figure 2.11. IESCO Organogram
IESCO ORGANOGRAM
BOARD OF DIRECTORS
IESCO
Manager Company Secretary
(Internal Audit)
Manager
Cheif Executive Of�icer
C&C
Audit Manager (Coord)
GM/ GM/ Executive

Operation GM/CS Technical Finance DG (IS)
DG (HR) DG (A&S) Director
Director Director Director Director (L&CA)
C.E/Sr. Deputy Manager Manager Manager

SE Manager PD (Constr) Manager
Manager Finance
GSO (Commercial) Director (HR) (Admin) MIS L&L
(O&M) T&G
C.E/Sr. Manager Manager
DM C.E/Sr. Manager Manager P&E Manager
Manager (CS & (CPC) (T&D) (TPT)
(PR)
(O&M) DIST Marketing)
C.E Manager DM
Manager (MM) Manager
Manager (C&PM) (Security)
(Sury & Inv) (CA)
Manager (M&T)
C.E
Manager (Development)
Manager (OPRS)
(Recovery)
Manager (Project
1. Islamabad Financing)
2. Rawalpindi City Manager
3. Attock (Procurement)
4. Jhelum
Manager (PS&C)
5. Chakwal
6. Rawalpindi Cantt.
PD (GSC)
Manager (Telecom)
Source: IESCO (Online: www.iesco.com.pk)
41
Power Sector
Action Points
▪ The organogram of the DISCOs needs to be corrected by downsizing the head

of�ices and strengthening the �ield of�ices.
▪ The strengthening of HR at the sub-division level is required.
▪ Sub-divisions and divisions must be merged at each circle of�ice, which would
convert itself into the primary business unit of the DISCOs.
Decision-making without Power Sector Experts
▪ The sector experts to run the power sector's affairs at the top level have been
completely ignored.
▪ The absence of sector professionals in the PD-MoE is a signi�icant reason

behind the weak governance and operational transgressions at the DISCOs.
There is a lack of vision but lust for holding of�ices by bureaucracy.
▪ Their blind dependence on donor advice (who do not know ground realities)
is responsible for an acute shortage of skills and capacity in existing employees_
both at the managerial and technical levels.
▪ The recent efforts to restore governance and strengthen the boards and senior
management is no different.
Action Points
▪ A serious effort is required to rebuild and strengthen the governance,

management, and technical skills and capabilities of DISCOs through
appointing/ involving power sector experts in DISCOs decision-making.
▪ Fitness/ merit should be the lead criterion in promotions.
▪ Training_ professional certi�ication programs must be held for of�icers of each

department within DISCO.
42
Power Sector
Board of Directors (BODs)
▪ Every DISCO has independent boards but the limited authority to make
decisions. All decisions are made in the PD by the bureaucracy.
▪ A signi�icant majority of DISCO board members are not power sector

specialists.
▪ Even after so many years, the GOP has failed to develop a proper board member
combination. As a result, no radical change has been realized concerning
customer service delivery through improved technical and commercial
performance.
▪ The BODs appointed in 2021 are inclined toward speci�ic groups and mindsets
(as explained in Chapter 1).
▪ They managed to block sector people with the expertise to bring about a change
in a planned manner. These BODs made a failed attempt to induct competent
CEOs of their choice from the open market. They were not even held accountable
for the expenditure incurred on the hiring processes of senior management.
▪ In the last eight years, some DISCOs hired individuals in managerial positions,
through these boards. But these left early as new appointees were un�it; their
selection was not on merit. The situation de-motivated the existing cadre, and
they could not adequately serve the clientele.
43
Power Sector
Action Points
To run DISCO affairs commercially requires an appropriate BODs. An independent/

apolitical board with suf�icient capabilities to develop a business model.
▪ A suitable combination of experts_ those who are aware of organizational

(DISCO) culture, the geographical & socio-economic environment in which it
operates, and the mindset and behavior of various consumer categories
towards electricity usage.
▪ Board members should be chosen bearing in mind con�lict of interest of
industrialists what demand bene�its from companies.
▪ Local people on the BODs for governance but no large users like industrialists
or commercial people.
▪ Bring in academics and non-political people on board.
▪ Mandate listing of the DISCOs in the stock exchange with a limit of 5%
maximum by one shareholder. Let the institutional investors come in and
manage the business.
▪ Sell a certain percentage of shares to DISCO employees and give them
representation on the board.
Out-dated Distribution Infrastructure
▪ Under CPEC agreements, the system added a signi�icant generation capacity

without upgrading T & D infrastructure.
▪ Lack of continuous maintenance and distribution operations in the under-
capacity system are the major causes of load shedding.
▪ A robust technical system for the economic dispatch of electricity is not in place.
▪ The distribution infrastructure is archaic_ mired in the 1960s technology.
▪ Lack of investment in the maintenance and upgradation of infrastructure has
affected the quality and standards in the distribution network. These are
deteriorating continuously. Thus, affecting supply security.
▪ DISCOs have failed to adhere to the prescribed standards required by NEPRA.
On the other side, standardization, upgrading of systems, assurance of standard
44
Power Sector
service etc., remains a blind spot for the regulator.
▪ Billing is still at the centralized level, and conventional meters are used at the
consumer end.
Figure 2.12. Pre-paid Smart Metering System
▪ Bene�its of advanced metering infrastructure is 6.6 times more

than the cost (Case Study of PESCO feeder, Shah and Khan
(2017)).
Bene�its ▪ Signi�icant Potential to reduce AT&C losses (about 20%
reduction in non-technical losses in Mozambique; increased
debt repayment and bill recoveries in UK & Australia; and
demand management in Canada and US.
▪ Smart meters costs 60-70% of total costs of pre-paid smart

metering system; two way communication system is about
15%; rest is the IT infrastructure at the utility and other costs.
Major Costs
▪ Cost of pre-paid smart meters (single-phase) plus installation
in Pakistan is about Rs 6000 to Rs 6500.
▪ Consumer pays for the meter cost in lumpsum or recovery

through bills in installments, and retro�itting old meters
(where possible).
▪ Global System for Mobile Communication (GSM) with support

for GPRS can be used as the primary communication channel
between smart meters and utilities; or outsourced to a Mobile
Options Virtual Network Operator (MVNO), a wireless system (trusted
third party).
▪ For compatible IT infrastructure upgradation at the utility and

O&M costs, allocate PSDP.
▪ Data management at the utility can also be outsourced to a

trusted third party
More details on pre-paid (smart) meters in Chapter 12.
45
Power Sector
Action Points
Revise distribution design and technical standards
▪ DISCOs must be upgraded at the earliest (max 3-5 years, depending on speci�ic
up-grade modules).
▪ Technology Innovations like higher distribution voltage (33KV instead of 11KV),
reduction in LT to HT lines ratio, smaller/individual transformers, smart
metering system, provision of auto-reclosures, and control devices like
sectionalizers are needed.
▪ Special modules in IT & AI; distribution SCADA, and allied tools must be
introduced under a maximum of the 3-year program.
▪ Re-designing the distribution system_ from individual service cables to the
provision of distribution boxes etc., duly sealed to ward off any chances of illegal
abstraction.
▪ The condition of LT protection switching on distribution transformers would
have to be re-introduced signi�icantly when the voltage is increased to 33KV.
▪ Appoint CTOs in each DISCO.
▪ No new connection without meeting technical standards; only those
connections are provided, which can pay for smart meters, system upgrades
through �ixed monthly charges, minimum consumption guarantees, etc.
▪ Move from a centralized billing system to decentralized billing system at
the DISCO level.
▪ Implement pre-paid smart meters linked to a decentralized DISCO billing system.
▪ The consumer will pay for these smart meters.
Through automation_ pay-as-you-go smart meters, and managerial and

administrative improvement, it is possible to eliminate inef�iciencies and losses.
▪ Socio-economic obligations of the government only if compliant with technical

standards.
▪ Due to price volatility, adequate funds must be ensured, as routine maintenance

is becoming challenging.
Only an affordable tariff in different geographical parts of the country can

enable effective revenue collection and improvement of �inancial health for
investment.
46
Power Sector
3. EXTERNALITIES AFFECTING ELECTRICITY DISTRIBUTION
Dealing with power distribution companies in isolation cannot alleviate its

challenges. The overall pro�ile of an area in which it operates plays a critical role
in its performance.
3.1. VARIATION ACROSS DISTRIBUTION COMPANIES
Each DISCO has its dynamics concerning:
▪ Technical parameters like LT/HT ratio, Transmission/HT ratio, number & health
of grid stations.
▪ Federal writ & provincial writ; and political will for the resolution of the issues
of electricity theft and revenue recovery.
▪ Demography, payment culture, socio-economic status of the populace.
▪ Consumer / consumption mix.
▪ Role of the criminal justice system and law enforcing agencies in DISCO
operating areas.
▪ Organizational culture of DISCOs and vision and mindset of senior management.

Logistics, equipment, and technical staff availability.
▪ In�luence of trade unions or of�icers’ associations.

▪ Safety policy.
3.2. EXTERNALITIES
▪ Dealing with power distribution companies in isolation cannot alleviate its

challenges. Understanding several related aspects can help in identifying
solutions.
▪ The success of DISCO operations depends upon the human development index
(HDI), per capita income and state writ in that distribution area.
▪ The level of power sector investments made in the vicinity of DISCO in�luences
its operational and commercial ef�iciency.
47
Power Sector
▪ Power sector operations are better in DISCOs in Punjab. It is not because of any
effort of the Power Division or DISCO. It is because of the better HDI, per-capita
incomes, the level of power sector investments made in districts falling within
these DISCOs' geographical boundaries, and because of the better writ of the
government in these areas (Figure 3.1 to 3.4).
▪ Once these facets are bettered/improved in Sind, KPK and Baluchistan, the
power sector operations in these provinces will surely improve. Otherwise,
the situation would remain the same.
Figure 3.1. District-wise Mapping of Human Development Index (HDI)
HUMAN DEVELOPMENT INDEX (HDI) Snapshot of Human Development in 2015

HUMAN DEVELOPMENT INDEX (HDI)
High HDI 0.800 or more
High Medium HDI 0.700-0.799 High HDI 0.800 or more
Medium HDI 0.600-0.699 High Medium HDI 0.700-0.799
Medium HDI 0.600-0.699
Low Medium HDI 0.500-0.599
Low Medium HDI 0.500-0.599
Low HDI 0.300-0.449 Low HDI 0.300-0.449
Very Low HDI 0.299 or Less Very Low HDI 0.299 or Less
Tharparkar
Source: UNDP Human Development Index (2015)
48
Power Sector
Figure 3.2. District-wise Mapping of Power Sector Operations
Source: PEPCO Statistics (2021)
Figure 3.3. District-wise Mapping of Per Capita Income
Source: Pakistan Bureau of Statistics (2021)
49
Power Sector
Figure 3.4. District-wise Mapping of Governmental Writ
Source: Pakistan Bureau of Statistics (2021)
Key Takeaways and Way Forward
▪ The future strategy for each state-owned company needs to be thoroughly

grounded in its service area's political, economic, social, environmental, and
urban governance realities. The same strategy cannot be applied to every
distribution company, as each works in a different environment.
▪ Secondly, for better administration of these companies, it is better to divide
them into smaller units.
▪ An effective crackdown against defaulters in high-security risk areas like in

PESCO, QESCO and even certain pockets in privatized KE, without law
enforcement agencies' support is impossible. The provincial governments must
support their respective distribution company in bill recovery, theft control
and protection of utility staff.
50
Power Sector
4. PRIVATIZATION OF DISTRIBUTION COMPANIES:

A FUTILE EXERCISE?
In Pakistan, as Stiglitz (2008) said, "the theoretical case for privatization is at

best weak or non-existent". Privatization of a natural monopoly (electricity
utility) does not guarantee ef�iciency.
Figure 4.1. Pre-requisites for Successful Privatization of Electricity Distribution
Easier said than done, as the National Electricity Policy 2021 af�irms the
continuation of uniform tariff, meaning continuation of tariff differential subsidy,
which is not an incentive for privatized utility.
Privatization of distribution utility successful only in large urban centers in

middle-income countries. DISCOS work in varied socio-economic and political
environments. Even within each DISCO jurisdiction, wide dispersion.
Electricity distribution being a natural monopoly, requires political support,

strong legal and institutional environment; missing in Pakistan.
Effective and well-informed regulatory environment; missing in Pakistan.
Over-staf�ing in state-owned companies. Easier for the privatized utility to target

employees rather than improve inef�iciencies, to increase their pro�its. The cost of
over-staf�ing is less than other inef�iciencies in the distribution systems.
Importance of contract the ability to make a good contract and to ensure its
implementation; incapacity of our bureaucracy in making a business agreement
and its implementation.
Managerial expertise_ highest bidder may not be the best manager; this factor was
ignored in the past privatization processes.
Source: Malik (2022a)
51
Power Sector
4.1. PRIVATIZATION OF ELECTRICITY DISTRIBUTION IN PAKISTAN: HISTORY
▪ The privatization of state-owned electricity distribution companies was a part

of the 1990s restructuring plan. The aim was to ease pressures on government
budgets, limit bureaucratic control and push for cost-effective pro�it-making
utility.
▪ Karachi Electric Supply Company (KESC), now K-Electric (KE), was the �irst
distribution company privatized.
▪ The privatization of KESC was initially intended to be the �irst in the broader
privatization program for remaining distribution utilities. However, the plan
was shelved because of the poor performance of KESC even after privatization.
▪ In 2013, the privatization of DISCOs again came under discussion as a solution

to generate ef�iciency in the distribution sector.
▪ The Circular Debt Mapping Plan 2015 envisaged that the revenue generated
through privatization would be used for clearing circular debt. But the plan
was again shelved.
▪ Yet again, as per the Privatization Commission website, all state-owned

distribution companies, excluding TESCO, are potential candidates for
privatization.
52
Power Sector
Box 4.1. K-Electric (KE) Privatization
The process concluded in December 2005 when 73.5% of government shares were sold to
Hassan Associates, Saudi Al-Jomaih Group of Companies and Kuwait’s NIG, and US$ 264.90
million was charged. The conglomerate guaranteed better services via professional
management, new investment, technology, and employment bene�its. It was agreed that
the buyer would invest US$ 500 million in the utility over three years, starting with US$ 75
million in the �irst phase (Abbasi, 2012).
The decision was taken so hastily that the outstanding stock of Rs. 18.1 billion (as
recoverable) was also handed over without the usual discount adjustments. The military
government at that time bypassed routine procedures. KE privatization was viewed as
illegal in political circles and challenged in the courts (Foster & Rana, 2019). In selecting a
private owner, its credibility had not been investigated. Against the agreement, and even
before due investments, the utility was re-sold to Abraaj Group in 2009.
As of now, under new management, the utility has partially improved its performance in
terms of service delivery_ the service to high-end areas of Karachi has improved compared
to low-end areas. From the consumer perspective, electricity tariffs are higher, but the
service quality has not improved much. Instead of mainstreaming deviant power
consumers, the utility still relies on revenue-based load shedding in areas with high AT&C
losses.
In addition to contractual obligations, it is the job of the regulatory authority to set and
enforce reliability targets and allow for tariff-based compensation to the privatized
electricity distribution company. These are the missing links in the case of KE. The utility
claimed that it is facing constraints in capital investments due to regulated tariffs, despite
being privatized.
The privatized entity has refused to abide by its privatization covenants. Besides, it has
refused to pay off NTDC (supplying more than 1000 MW each day) and SSGC (supplying a
max. 280 MMCFD of gas), leading to a default of about Rs. 400 billion at present. The utility
wants this outstanding amount to be netted against its TDCs (subsidies) against the GOP.
The GOP has been unable to get KE to sign the PPA. The earlier one expired in January 2015.
Besides, given the current tariff structure and subsidy policy, KE, since FY2007, has
received Rs. 478 billion only under the tariff differential head. Before FY2014, KE also
received government support to pick up payables for PSO and Gas companies. This
indicates that the primary objective of minimizing the burden of subsidies through the
privatization of KE has yet to be realized. Due to delays in tariff determination,
disbursements of TDCs, and receivables from the government departments, the
receivables from KE have gone up to Rs 225 billion. Thus, adding to the CD burden.
The city of Karachi has its dynamics_ weak governance and fragmented institutional
structure affecting utility performance. The utility faces delays in tariff determination,
delays in the disbursements of TDCs, and delays in receivables from the government
53
Power Sector
departments. Theoretically, it should have been relatively more straightforward for KE to

make investment decisions to upgrade or replace distribution infrastructure as a
privatized company. However, the company still needs regulatory approvals from NEPRA
(Malik and Khawaja, 2021).
4.2. LESSONS FROM K-ELECTRIC PRIVATIZATION FOR OTHER DISTRIBUTION

COMPANIES
▪ The electricity distribution utility (monopoly), despite being privatized, cannot

operate without the support of Federal, Provisional, and Local Governments.
▪ The revenue requirements of the distribution utility must be funded through

billing and on time. The subsidies, direct or indirect, must be paid up on time.
▪ Government consumers must pay the entire bill on time.
▪ The distribution companies cannot operate and deliver until the externalities
affecting the ef�iciency of the utilities continue. That is if the culture of theft
and non-payments of the bill remains prevalent in the service area.
▪ Explicit contractual terms are needed to guarantee that private operators

invest in the distribution infrastructure. The expertise required to make and
implement good privatization contracts does not exist in bureaucratic circles;
bureaucracy may end up with the wrong decision.
▪ At the same time, any de�iant distribution company operator can play havoc
because of its monopoly power and the ability to blackmail the government.
▪ Any possible privatization is far away as a solution to the ever-increasing

burgeoning CD.
4.3. PRIVATIZATION OF MONOPOLY
▪ The public sector has a social responsibility, while private operators aim to
maximize pro�it. Society is an ultimate loser if both perform carelessly.
54
Power Sector
▪ Service ef�iciency and reduction in tariffs for consumers can be ensured only
through competition.
▪ Privatization of a utility (natural monopoly) does not guarantee competition.

The privatized monopoly increases pro�its at the expense of consumers and
employees.
▪ The post-privatization monitoring (regulatory) mechanism has remained weak

in Pakistan. The regulator remained busy determining tariffs rather than
regulating a monopoly.
▪ A proper regulatory framework and contract enforcement are necessary for a

company to abide by its commitments. In Pakistan, like most developing
countries, weaknesses in the electricity sector's regulatory processes compromise
the ef�iciency of both private and state-owned distribution utilities (monopolies).
▪ There are economic, social, and political costs associated with the privatization
programs in Pakistan. Economic policymaking in Pakistan has continued to be
a matter of rent-seeking between contending interests.
Experience of privatization in Pakistan indicates it was the privatization of state assets

for the private parties by the private parties.
The KE experience suggests that the private sector can better manage distribution affairs
than the bureaucracy. However, the management performs best in an effective regulatory
framework with incentives/ penalties and supportive city dynamics and governance
systems. Independent control of a state-owned company can also serve better.
55
Power Sector
Box 4.2. Case of North Delhi Power Ltd. (NDPL)
NDPL_ a joint venture between public (49%) and private ownership (51%) w.e.f. July 1,
2002, devised by the Delhi Government. It is the sole agency to distribute electricity to most
of North and North-West Delhi.
Soon after the deal, NDPL chooses a team of performers to head each functional area. NDPL
appointed a competent CEO with substantial management experience in the private power
company.
In the transition, the Delhi Government provided �inancial support through subsidized
power purchases for �ive years and a better speci�ied multi-year tariff-setting regime based
on more realistic loss targets. The subsidies were intended to avoid post-privatization
tariff increases. It was a well thought out deal by the Delhi Government.
Indian Rs. 12.5 billion capital expenditure plan for �ive years was made. AT&C losses
reduced from 53% to 20% and system reliability improved signi�icantly. In 2021, NDPL
AT&C's losses stood at 7.5%. The steps taken towards reducing this loss included: energy
audit of the distribution network, rationalization and updating of billing database,
installation of low tensionless systems in theft-prone areas, replacement of faulty meters,
and aggressive enforcement activities. The company became cash-suf�icient too. The focus
in NDPL remained on quality, training, performance-based incentives and employee
welfare, technology, and innovative systems.
No forced downsizing was adopted; instead, it offered an attractive voluntary retirement

scheme. The NDPL ever introduced no revenue-based load shedding or outright power
cuts. Because of the near-complete indigenization of generation fuels in India, the power
tariffs have retained their earlier levels in India. Currently, no subsidy or cross-subsidy to
any NDPL consumers, but some support payment by the government for speci�ic electricity
usage.
Sources: Saini and Bhatnagar, 2005; Of�icial websites of power companies in India
▪ The future strategy for each state-owned company needs to be thoroughly

grounded in its service area's political, economic, social, environmental, and
urban governance realities.
▪ The same strategy cannot be applied to every distribution company, as each

works in a different environment.
56
Power Sector
▪ Handing over management to the private sector while keeping the majority of
assets in state ownership is an option. A similar arrangement was successfully
adopted in NDPL in India (Box 5.2). With 49% government shares, the Tata
Group (the main stakeholder in NDPL) never considers the utility a pure
business14 .
▪ Beyond that, there is strong resistance to change at the DISCO level15.
Action Points
▪ Outright privatization may increase the �inancial burden on the government. At

best, slice the distribution companies into smaller units. Then a management
contract of selected areas (urban) and not the entire distribution sector.
▪ The GOP could do it through a time-bound management contract or even a

mid-term concession to an able management team supported by a credible
�inancial entity.
▪ Pakistan Energy Council & NEPRA must lay down the pre-requisites for the
envisaged management contracts. First of such contracts may be given in a
maximum of the coming six months.
▪ As mentioned earlier, mandate listing of the DISCOs in the stock exchange with a
limit of 5% maximum by one shareholder. Let the institutional investors come in and
manage the business.
▪ Under the Essential Services Act, the GOP must temporarily bar Trade Union
activities in these entities (if not permanently). Otherwise, the envisaged
management contracts will not work.
14 In KE, 25% stakes are held by the GOP, and 2 to 3 Directors on the Board at various times. The governmental
nominees either do not attend the meetings or participate half-heartedly.
15 Privatization or related plans to change the institutional setup in DISCOs create uncertainty among employees.
These policies or reform plans face strong employee resistance, joined by the CBA and officer's associations.
57
Power Sector
5. GENERATION BLUES
The wrong policies under the grab of correcting mismanagement and random
decision-making to correct power sector de�icit resulted in the declining
performance of public sector generation plants.
5.1. INTRODUCTION
Public sector generation plants (GENCOs) are running below their net available capacities.
The timely maintenance and scheduled outages over the years as per standard industry
practices have not remained in place. Lack of maintenance has increased their generation
cost. Using similar fuel, these plants' EPP is higher than IPPs. The Framework of Economic
Growth by PIDE (2020) reports that Rs 251.6 billion was lost due to inef�iciency in these
public sector generation companies (Table 5.1).
Table 5.1. Losses in GENCOs, 2010
Capacity Loss: Mismanagement 1,500MW Rs 130 billion
Ef�iciency loss: Mismanagement on average 5% Rs 8.6 billion
Extra use of fuel: Inefficient plants Rs 103 billion
Leakage: Fuel Supply estimated Rs 10 billion
Source: PIDE: Framework of Economic Growth (2020)
58
Power Sector
Power Sector
Table 5.2. Capacity Installed and Generated
FY2017 FY2021
GENCOs
Installed Capacity Generated Units Installed Capacity Generated Units
(MW) (GWh) (MW) (GWh)
I 1,024 3,593 880 199.04
II 2,402 8,079 1,790 4,824.29
III 2,293 6,861 2,061 1,777.26
IV 150 124 --- ---
▪ The total electricity generation of GENCOs during FY 2020-21 remained at

6,802.93 GWh compared to 7,907.85 GWh during FY 2019-20, showing a
decrease of 1,104.92 GWh.
▪ NEPRA, in FY 2021, decided to convert the tariff of all old blocks of GENCOs
from a ‘take or pay’ to a ‘take and pay’ basis_ to reduce capacity payment
obligations (NEPRA, 2021).
▪ Over the years, policymakers have focused on new projects in the private
sector rather than maintaining the available capacity, thus hurting their
ef�iciency, and putting costly electricity in the system (Malik, 2020).
59
Power
Power Sector
Sector
Table 5.3. GENCO’s Ef�iciency and Utilization
GENCOs Net Efficiency % Utilization Factor %
FY2017 FY2021 FY2017 FY2021
I TPS Jamshoro 28.42 27.37 58.04 0.88
GTPS Kotri 27.06 0 33.51 0
II Guddu 1-4 25.67 0 12.34 0
Guddu 5-10 36.03 32.01 47.33 31.06
Guddu 11-13 30.09 22.26 36.03 6.46
Guddu 14-16 48.70 55.55 69.43 48.93
Quetta Isolated 19.95 0 24.35 0
III TPS Muzaffargarh 29.76 32.5 48.21 3.02
GTPS Faisalabad 23.86 0 14.52 0
SPS Faisalabad 28.40 21.01 12.27 1.62
TPS Nandipur 39.62 46.53 38.52 33.73
IV FBC Lakhra 18.34 0 22.68 0
Source: NEPRA: State of Industry Report (2021)
60
Power Sector
5.2. GENCOS: HISTORICAL PERSPECTIVE
Box 5.1. GENCOs Journey (1958 to 2022)

GENCO’s journey started in 1958 after enacting the WAPDA Act 1958
▪ A structured expansion in generation from the late 1980s to the early 1990s_ the
completion of 1350 MW TPS Muzaffargarh, the 1650 MW GTPS Kot Addu and the
850 MW Jamshoro TPS.
▪ With the support of the Planning Commission, Lakhra Coal Development Company
was established as a joint venture of WAPDA, PMDC, and Sindh Coal authority. WAPDA
was the lead partner with 50% shares.
▪ After ensuring coal availability, WAPDA built its 150 MW FBC (3x50 MW steam
turbines) coal-�ired power plant close to the Lakhra coal mine. The plant had many
teething problems and could not generate power at a sustainable level. It was leased
out but through a �lawed process. The lease got challenged in the courts and cancelled
eventually. The plant deteriorated during the whole legal process and �inally shut
down.
▪ But during the whole legal process, the plant deteriorated and �inally shut down1.
In 1987, through a presential order (one-page policy), the GOP restricted the public sector to hydropower
projects and left thermal generation for the private sector. After the Power Policy in 1994, it was
formally implemented.
▪ HUBCO (1292MW) in 1992, 16 more IPPs under the 1994 policy with a capacity
of 31,00.5 MW were added to the generation system.
▪ KAPCO, with a capacity of 1,638MW, a public-sector power project, was privatized
and converted into IPP in line with the 1994 Power Policy. The addition of private
power plants led to surplus capacity in the system.
▪ The policy to bar the public sector from entering & owning thermal generation
continued even after FY2006 when the surplus capacity converted into de�icit.
Additionally, the lack of cash �lows affected the timely renovation of existing GENCOs.
▪ Adding one hydro IPP (84MW) under the 1995 Power Policy and 15 more thermal
IPPs with the capacity of 3,267MW under the 2002 Power policy could not reverse
the situation_ the power shortage continues.
▪ In 2008, with a shift in policy, three power plants (in the public sector) were allowed_
Nandipur (525MW)2, Chichu Ki Malian (525 MW)3 and the addition of gas turbines to
Guddu Power Complexes (to increase its capacity to 1,762MW)4.
1 PEPCO’s Public Sector Generation Capacity Enhancement Plan (2010) did contain a renovation of this plant
at a meagre cost of US $9 million. The process withered away with PEPCO’s demise in 2011 and with the
setting-up of GHCL.
2 It is a CCGT power plant run on dual fuel. It faced a series of delays during and after the launch of its commercial
operations because of political and commercial disputes, court inquiries, audits, etc.
3 The power plant faced delays and later got shelved.
4It is one of the most ef�icient public sector power plants. It is the National Grid’s mainstay in the South and
a potential candidate for privatization.
61
Power Sector
5.3. RANDOM DECISION MAKING
To correct the power sector de�icit, the GOP (2013-18) added :
▪ Four RLNG_ combined cycle power plants in Punjab (Haveli Bahadur Shah
(1,230MW), Bhiki (1,180MW), Balloki (1,230MW) and Trimmu (1,263MW)
▪ Two coal-�ired power plants (CFPPs) were added, one at Sahiwal (1,320MW)
and the other at Port Qasim (1,320MW) under CPEC
The four RLNG plants are located not only quite far from the Karachi or Gawadar port but
are dependent on timely imports. The average plant factor is below 58% against the
accepted minimum of 85%. In the case of RLNG shortage, the secondary fuel used is HSD.
It means a high generation cost whenever there is a surge in the import price of RLNG or
a de�icit of RLNG. Besides, RLNG supplies must accommodate the loss or UFG of 7%,
further compounding the issue of costs. Likewise, Sahiwal's CFPP should not have been
allowed. It requires 1200Km of rail journey to transfer imported coal from the port to the
plant site_ increasing the cost of electricity generation, apart from the environmental
consequences.
▪ A non-professional approach at GHCL and mistakes in decision-making led to

the continued national loss.
▪ Historically (in the early WAPDA days), all public sector generation plants were
planned professionally regarding site and fuel selection.
▪ Similarly, all IPPs (under 1994 and 2002 policies) could have been located
elsewhere, provided all the departments tasked to deal with investors had
performed their duties responsibly. Unfortunately, the focus of these departments
(i.e., PPIB) had remained on bidding only.
▪ None of the departments (PPIB, AEDB, NTDC, NEPRA, PEDO, PPDB, Sindh
Energy Department & CPPA-G) meets its job pre-requisites.
16 There were delays in the commissioning of the IPPs in the pipeline.
62
Power Sector
Box 5.2. Solar Power Parks_ A Case of Quaid-e Azam Solar

Power Park (QASPP
There are prerequisites for setting up a Power Park, for instance, acquiring land, arranging
transmission lines to evacuate power, soliciting approvals from local bodies etc. The private
sector is more skilled in operating power plants in these parks. But they face dif�iculties unless
all the prerequisites are facilitated/ provided by the government beforehand. It saves time and
lowers costs. In 2012-13, the PPDB efforts for the QASPP came to a standstill as neither
prerequisite was in place nor planned.
Likewise, the park's location is also important, where the government invites the right kind
of technology and sets tariffs through competitive bidding. QASPP is not only erroneously
located but managed inappropriately. QASPP is located in the desert of Lal Sohanra, Bahawalpur,
where summer temperatures go up to 48oC. Higher temperature reduces the ef�iciency and
life of the solar plant. Transmission infrastructure to transmit 1000MW is now put in place;
still, due to heat factors and managerial issues, even after so many years, only 400MW can be
produced and evacuated from this plant.
The bidding process was not as per international norms, thus resulting in high tariffs. Park is
set in Punjab in isolation, with no design skills. The little bit of power generated is expensive
and burdens the consumer.
In India, setting and operating power parks yield positive results_ affordable tariffs for consumers
and the operations of plants at very high plant factors. The reason is proper planning; the
government makes all prerequisites available timely.
Key Takeaways
Over the years, wrong policies, and random decision-making to correct the power sector
de�icit resulted in the declining performance of public sector generation plants. For
instance, in recent years, wrong location and selection of fuel types highlight quick �ixes
without vision and planning.
In the pre-reform era, WAPDA always preferred site and fuel use in plant selection, i.e.,
location close to the load center and the fuel at the least cost with a guarantee of supplies.
The RLNG power plants, if located near the two ports, would have curtailed costs to some
extent. These plants could have been installed at the present site of the thermal power
plant Jamshoro17, where evacuation lines are already available.
17 There were delays in the commissioning of the IPPs in the pipeline.
63
Power Sector
6. IPPS THAT CHANGED THE POWER ARCHITECTURE

IN PAKISTAN
Every policy initiative has been in�luenced by one or the other donor agency, strategic
partner country or interest group. Lack of transparency and an independent regulatory
audit, IPPs are getting paid for the electricity they have not generated, increasing the
cost of generation.
As of June 30, 2021, Pakistan’s total installed capacity stands at 39,772MW, generating
electricity equivalent to 143,589 GWh.
Figure 6.1. Installed Capacity (MW)
25,000 50,000
45,000
20,000 40,000
35,000
15,000 30,000
25,000
10,000 20,000
15,000
5,000 10,000
5,000
0 0
1982 1991 2001 2006 2012 2016 2020 2021 2022
Source: NTDC Electricity Marketing Data (2022) and NEPRA State of Industry Reports (Various Years)
64
Power Sector
Figure 6.2. Generation Capacity (GWh)
90,000 180,000
80,000 160,000
70,000 140,000
60,000 120,000
50,000 100,000
40,000 80,000
30,000 60,000
20,000 40,000
10,000 20,000
0 0
1982 1991 2001 2006 2012 2016 2020 2021 2022
6.1. BEGINNING OF IPPS ERA IN PAKISTAN
Through a one-page policy paper in 1988, the GOP paved the way for private generation
companies in the country. In 1992, the GOP prepared a strategic plan for the electricity
sector restructuring. For generation capacity expansion and ef�iciency, the plan realized
the role of the private sector.
Box 6.1. Hub Power Plant
The feasibility of the �irst private power project, HUBCO, with a capacity of 1292 MW, was
completed in 198818. In 1991, HUBCO became a Limited Liability Company for executing the
project in Pakistan. In 1992, the plant signed an agreement with WAPDA to develop a 1292
MW power plant. The WB supported the project and helped arrange the �inances. The global
�inancial market cited this project as the �irst major private sector venture executed in any
perilous developing country environment. HUBCO was the �irst private sector generation
project that entered the system in 1997. Its generation license will expire in 2025
18 Signed by General Zia ul Haq.
65
Power Sector
In 1994, GOP
Power Policy 1994
In 1986, GOP formulated a
offered generous
encouraged the comprehensive
tariffs & bulk of IPPs were allowed
private sector on power policy for 19 IPPs started
other incentives for to sell electricity to
BOO basis, but the �irst time to their operations
the private WAPDA and KESC
response was not allow private in Pakistan
generation plants under PPAs
encouraging sector to invest
based on HUBCO
in the generation
experience
sector
In the 1990s, Pakistan opened its generation sector for the private investors under external
pressures (WB) and vested interests of those in power, including powerful bureaucracy19.
These projects did not meet the "least cost" generation test because of their small size,
unsuitable location, and excessive reliance on oil and steam turbine technology instead
of more ef�icient CCPPs. The advent of the �irst IPP (HUBCO)20 led to unwarranted �inancial
pressure on WAPDA while leaving nothing to re-invest to upgrade or maintain the existing
generation system in the public sector21 .
▪ Private sector does contribute to the expansion of generation capacity in Pakistan,

the absence of cost-effective planning increases generation costs.
▪ Absence of competitive bidding for private generation projects and non-transparent
procurement processes raised concerns about the potential for corruption.
▪ Sovereign guarantees offered by the government aggravate �inancial problems.
▪ The power sector became a major cause of the rise of public debt in the late
1990s.
19 The WB also got involved in arranging �inances for HUBCO from the governments of France, Italy, Japan,
United Kingdom, and the United States as co-�inanciers in the Private Sector Energy Development Fund of Pakistan.
This fund along with the WB and the Import/Export Bank of Japan jointly developed an Expanded Co-Financing
Operations Program to assist the international commercial debt funding by the provision of a partial guarantee.
A signi�icant portion of the offshore debt was also guaranteed by certain export credit agencies. A group of local
banks led by the National Development Finance Corporation of Pakistan provided rupee debt (HUBCO, 2021).
20 From 1985 to 1992, various policies were framed and announced to encourage and mobilize private participation,
but only HUBCO came. Despite several concessions/facilities assured by the GOP, the HUBCO implementation
progressed at a snail’s pace.
21 During 1995-96, the Chairman WAPDA (a generalist civil servant) and the Member (Finance) did nothing
but remained busy arranging money to pay HUBCO. This affected cash �lows at WAPDA.
66
Power Sector
▪ Even to date, capacity payments to IPPs are one of the key reasons behind high
electricity costs/ prices and rising CD.
6.2. WRONG DECISIONS AND IPP IRREGULARITIES
Pre-2015 Era
▪ After the detailed audit of HUBCO and other IPPs (commissioned under the 1994
Power Policy), the GOP started a criminal investigation in the late 1990s. Some
sponsors were arrested, while others were forced to re-negotiate their PPAs.
Protracted litigation by the HUBCO sponsors, which got settled in 2000 by the
GOP/WAPDA through re-negotiated PPAs of all IPPs (sixteen with a capacity
of 4,393 MW).
▪ Rates were brought down substantially for a few IPPs but remained nearly the
same for the giant, HUBCO.
▪ HUBCO PPA retained its offending conditions and tariff, while the small IPPs
viz. SEPCOL, Japan Power and Saba Power have been shut for the last twelve
years because of �inancial losses.
▪ Electricity consumers paid the debt portion of these IPPs through tariffs but
failed to get lower tariffs even after that.
▪ Power Policy 2002 attracted the Pakistan corporate sector instead of international
investors.
▪ 2002 policy was meant to do away with the one-sided facilitation for the IPP
sponsors22. Yet, it ended up with more facilitations for the private producers
at the expense of the sector’s future and consumers. It attracted plants with
expensive fuel mix.
▪ In 2007, another policy was issued to counter all negatives of earlier policies,
i.e., competition instead of the cost-plus formula for the IPP tariff. It was stillborn,
thus, quickly taken back.
22 Signed by General Zia ul Haq.
67
Power Sector
Post-2015 Era
▪ 2015 Power Policy resulted in the induction of RLNG-fueled CCPPs and CFPPs.
The �ive mega-plants were set in Punjab instead of around Karachi, increasing
transportation costs – adding to the already bloated tariff.
▪ Four RLNG plants (1,250MW each) were set up with obsolete technology,
ballooned costs, and were allowed through dubious bidding processes.
▪ CFPPs were also set at high costs (as per cost sheets submitted to and accepted
by NEPRA), leading to the approval of high tariffs.
▪ In 2019, instead of inducting wind power, the GOP, through the PD, against its
noti�ication of moratorium to IPPs using imported fuel, allowed another RLNG
plant (1,250MW) in Punjab.
▪ With the inclusion of RLNG plant, the space for other types of power plants –
including renewable energy plants almost diminished23.
▪ The 2015 policy sought bid-based lowest tariff; NEPRA accepted as many as
12 wind projects of 50 MW each based on cost-plus formula24. The AEDB has
not drafted the bidding process and allied documents/procedure(s).
23 Wind Projects in Sindh (dozens of LOIs issued by GOS) were put on hold apparently for competitive bidding
per policy.
21The tariff allowed by the regulator is between 3.4 to 3.7 US cents on the levelized basis – against up to 13.5
cents given a few years ago. Costs of wind and solar plants have decreased substantially over the years.
68
Power Sector
Table 6.1. Power Policies and Impact on IPPs
Policy Salient Features Impact
1994 Investors free to choose site, technology & fuel; long- 16 furnace oil & gas based IPPs, with
term PPA & FSC with GOP guarantee; bulk power capacity of 4100MW were added to the
tariff of US Cents 6.5KWh_for �irst ten years, levelized system.
tariff of US Cents 5.9/KWh over life of the project (25-
These IPPs invested Rs 51.8 billion &
30 years) & a premium of US Cents 0.25/KWh in �irst
have earned more than Rs. 400 billion.
ten years; two part tariff_ CPP & EPP, CCP to be paid
on an annual plant factor of 60% on take or pay
basis; exemption from certain taxes & import duties;
& repatriation of equity along with dividends.
1995 Project on BOOT basis, GOP owner after 25 years; Insigni�icant response_ only one project
bulk tariff of US Cents 6.1/ KWh; exemption from with capacity 84MW was installed with
certain taxes & import duties; & guaranteed foreign long-term contract & GOP guarantee for
exchange conversion facility. 25 years.
1998 Competitive bidding & tariffs, two-part tariffs_ CPP & Policy failed to attract new investments.
EPP; guaranteed foreign exchange conversion
facility; restriction on imported fuels; & limited
exemptions on taxes & duties.
2002 PPA & FSC with GOP guarantees; hydro projects on 13 IPPs with capacity 2934MW; IRR
BOOT & thermal projects on BOO or BOOT basis; two- 15%; & project life 25-30 years; furnace
part tariff_ CPP & EPP; tax exemptions & financial oil & gas-based plants.
incentives; & no restriction on imported fuels.
These IPPs invested Rs. 57.81 billion &
earned (so far) Rs. 152billion.
2006 Exemptions on taxes and import duties; permission to 24 Wind IPPs with capacity 1234 MW
deport equity along with dividends; allows both cost- and 7 solar IPPs with capacity 430 MW
plus and upfront tariff regime. were set up. 8 IPPs with capacity of 253.7
MW have attained COD under 2013
(In 2013, GOP expanded the 2006 policy to include
Framework.
bagasse, biomass etc.; and issued the Framework for
Power Co-generation 2013) These IPPs have earned excess pro�its on
account of incorrect IRR calculation
(18.39% instead of 17%).
2013 Reliance on less expensive fuels; upfront tariff ------

mechanism; one window operation to facilitate
investors; whereas incentives given in 2002 remained
intact.
2015 Two-part tariff; PPA with GOP guarantee; hydro 7 IPPs with capacity 8253MW; IRR 15%
projects on BOOT (30 years) and water use charge to 17%; and project life 20-25 years;
@0.425/KWh to be paid to the province where the Imported coal and RLNG based plants.
project is located; thermal plants on BOO basis_ both One imported coal power plant
indigenous and imported fuels; three types of thermal recovered 71% of its investment in two
projects_ through competitive bidding, through years of its operation, and the second one
provincial recommendation, or based on 32 % in the same period. These plants
international commitments. have been offered 17%IRR in US$.
69
Power Sector
Similar stories are repeated in the history of private energy projects, whether under the
1994 Power policy, 2002 power policy or 2015 generation policy. There are always
transparency issues in the selection of projects, the role of pressure groups (local and
international), and political patronage. All the time, policymakers have chosen the path
of tariff ceiling to attract investors rather than competitive bidding.t
▪ All generation plants (except for renewables, e.g., wind and solar) are designed
with capacity payments, but there is hardly any monitoring of actual capacity
(as per capacity payments) and availability.
▪ There is no veri�ication of IPPs claims of power supply and what they supplied.
▪ Lack of transparency and an independent regulatory audit_ IPPs are getting

paid for the electricity they have not generated. This is increasing the cost of
generation.
None of the policies could be termed as public policy formulated for the betterment of the
people. All these were/ are Special Purpose Vehicles (SPVs) – crafted to meet the special
interests of speci�ic groups of raiders_ these were successful in their intent but led to the
near-collapse of the Power Sector. The GOP unveiled the new Electricity Policy in 2021.
It is no different from the earlier ones.
A comprehensive report was prepared by the committee led by the former chairman of
SECP in 2020 on the power sector, focusing mainly on losses because of IPP irregularities
(Box 6.2). Later, the government renewed PPA with 46 IPPs (Box 6.3).
70
Power Sector
Box 6.2. Power Sector Inquiry Report 2020 Findings & its
Aftereffects
▪ Fraud committed by the IPPs under three groups viz invoicing errors, wrongful interpr-
etation of the PPAs and blatant over-invoicing of plant costs.
▪ IPPs have skimmed the Power Sector by a whopping Rs.4.0 trillion during the last twenty
years (Rs.200 billion each year).
▪ Report unearthed only 50% of the issues and suggested a detailed forensic audit of these
IPPs.
▪ Even after the inquiry report, the tardy progress in remedying the situation is an issue
of concern.
▪ GOP signed MOUs with the IPPs through Independent Power Plants Association (IPPAC)*
and ignored the detailed forensic audit of IPPs.
▪ GOP has forgotten to tackle the 11,368 MW of IPP capacity** in the pipeline in the next
ten years.
▪ IPP billing of the above projects would signi�icantly impact the generation price in the
coming years; compliant electricity consumers would still be at the receiving end & the
▪ IPPs will continue making un-due pro�its.
*IPPAC is not registered with any regulating agency
** https://www.ppib.gov.pk/upcomming_ipps.html
Box 6.2. Power Sector Inquiry Report 2020 Findings & its
Aftereffects
46 IPPs have formally signed new agreements with the GOP, paving the way for a discounted
tariff of Rs 836 billion in the next 12 years. As of February 08, 2021, Federal cabinet committees
approved the payment of dues worth Rs. 403 billion in two instalments to these IPPs_ 40 per
cent in a month (one-third in cash, one-third as Pakistan Investment Bonds (PIB) and one-third
in �ive-year Islamic Sukuk) and the remaining 60 per cent in six months in similar three forms.
The present-day calculations of dividends for the next 20 years are Rs.770 billion or Rs.35
billion per year. Surprisingly, no refund is being contemplated for periods before signing any
agreement with the delinquent IPPs. Rs. 403 billion (the current outstanding payables) is to
be paid nearly upfront to the same IPPs. They are responsible for wrongful invoicing, incorrect
interpretation of PPAs and outright fraud without any deduction.
Power companies are unhappy with the development as their future earnings decline after
removing dollar indexation from their return on equity. From the power sector perspective,
the agreement would not substantially impact tariffs and circular debt, as it covers less than
23% of the installed capacity.
▪ CPEC power projects (8,913 MW) commissioned and in the pipeline (7,028.7 MW) under
the 2015 Power Generation Policy are not part of this agreement.
▪ The impact of dollar indexation would be on future earnings, while the projects commissioned
under 1994 are either retired or about to retire in a few years.
71
Power Sector
6.3. ROLE OF SEVERAL PARALLEL ENTITIES
A combined ineffectiveness of NEPRA, the PPIB, the AEDB and the CPPA(G) has been the
main reason for allowing windfall gains for the IPPs at the cost of consumers. Extra-billing
by the IPPs under all heads up to Rs.200 million each year (based on the FY2020 exchange
rate), i.e., 20% of actual costs and equivalent to Rs. 2 per electricity unit sold each year.
The investors successfully intimidated the PPIB, the AEDB and NEPRA to have their numbers
accepted in the face of totally different data and �igures being manifested elsewhere in
the world25.
PPIB & AEDB
▪ PPIB and AEDB are small and autonomous organizations with independent
members on boards other than those directly related to the power sector.
▪ No hard-core professionals on these boards; these entities relied upon a POEs

hired to scrutinize individual solicitations/projects.
Continuity in hiring depends on the PPIB / AEDB and the investors. As proved
by the longevity of POEs, all the IPPs ended up with similar problems. For
instance,
▪ The most common (as pointed out in the Inquiry Report) is the over-invoicing
of projected costs (high energy price costs) of the IPPs.
▪ Serious issues in project loans_ as these are left to investors to arrange and
structure; all the international loans are at the higher end of spreads.
O&M contracts are commissioned not by the OEMs themselves (as required
in the PPAs); instead, are negotiated with set-ups accredited with the OEMs
but independent.
▪ All these issues have not been accorded due importance, given that these have
profound rami�ications in the shape of high tariffs.
NEPRA
▪ Policies allowed unreasonably high pro�its to IPPs; excess payments have been
made to power producers because of either misreporting by the producers
and/or regulatory oversight (Report on the Power Sector, 2020).
72
Power Sector
▪ Pro�its generated were as high as 18.26 times the investment, and dividends
were taken out as high as 22 times the investment (Report on the Power Sector,
2020).
▪ Though NEPRA is not involved in the review and approval of PPA, it determines
the generation tariff that will apply to a power plant, and the PPA must follow.
Section 3(6) of NEPRA Licensing (Generation) Rules, 2000, allowed NEPRA for
additional terms and conditions for a good cause. It is the lack of regulatory
oversight that today Pakistan’s power sector is in a “capacity trap.”
CPPA (G)
▪ The CPPA(G) below-par working further adds to the excessive charging by

the IPPs.
▪ Most of the issues relating to wrongful and incorrect invoicing by the IPPs, even
interpretation of PPAs and speci�ic clauses leading to increased IPP invoicing,
are the main reason for extra charging by the IPPs; unfortunately, have escaped
the audit and check by the CPPA(G). All this happened because the CPPA(G)
processes and clearance of IPP billing / invoicing have never been put up to
any audit by the AGP.
▪ The CPPA(G) remained oblivious to the various clauses of the PPAs, their true
meanings, the requirement to be vigilant, and the obligations of a clearing house.
▪ CPPA(G) board is no different from other entities.
Recently, a plan has been prepared to install 10,000 MW of solar plants at the GENCO sites,
in certain high-load feeders, rooftops of government departments etc., to reduce the fuel
▪ bill. Preference to GENCO sites is given as the transmission and other ancillary
import
infrastructure is already in place. In the last approved Integrated Generated Capacity
Expansion Plan 2021-30, 22,182 MW is already committed for the period, and this
10,000MW solar project was not part of these.
Are we heading towards another haphazard decision? Does the economic viability of such
a project in those sites is evaluated? What type of investment will be in these solar plants?
The answers to these questions are yet to be known.
73
Power Sector
Pakistan’s Power sector needs private investment but without concessions, exemptions, and
government guarantees.
Action Points
▪ Whatever has been agreed with the IPPs, the right way would be to immediately
commission the required forensic audit, followed by recoveries without any relaxation.
▪ As an interim measure, the presently signed MOUs must be implemented on the fast
track.
Private auditors cannot ensure complete and the needed transparency of operations. The
private sector management can manipulate these auditors by doling out dividends.
▪ Therefore, post audit (within 3 to 6 months of the clearance of any IPP invoice) by the
AGP should be made compulsory.
▪ All power projects from 1994 onwards, primarily the CFPPs at Sahiwal, Port Qasim,
Hub Chowki, Gwadar (in the pipeline) or in Thar (through local coal), must be tackled
with the same brush. All of these are heavily over-invoiced and privy to undue bene�its.
In future
▪ Moratorium on IPPs in the short-term, including the proposed solar projects of 10000
MW.
▪ The process of replacing solar capacity with the existing candidate projects on fossil
fuels must be through a thoughtful approach and after gauging its effectiveness.
▪ In the future (long-term), no sovereign guarantees, and all investments must be based
on competition, the �inancial dynamics of the sector, and through a comprehensive
planned process.
▪ GOP should only acquire the new generation capacity through tariff bidding. It could
be done if the capacity in the pipeline is corrected, and the competitive bidding
documents are in place.
▪ To strengthen energy functions under the existing institutional setup will not lead to
sustainable solutions.
▪ So many parallel sector entities with limited capacity cannot safeguard people's interests
_ needs to reduce the number & strengthen the remaining. No need for PPIB, AEDB or
even CPPA-G; shut down these while consolidating NEPRA (more details in Chapter 12).
74
Power Sector
7. POWER CONTROL AND ALLIED ISSUES
The ability of power systems to ensure a continuous supply of electricity to customers

in the event of a disturbance is crucial. NTDC is not fully compliant with industry
standards. Codes of conduct on the safety, reliability, stability, integrated operability,
and ef�iciency of the electric power system are weak.
7.1. LOAD DISPATCH CENTER (LDC): HISTORY
Under WAPDA, the power system proliferated with thermal power plants in the south and
hydel power plants in the north.
LDC was established at Kot Lakhpat, Lahore, for transmitting electricity.
By 1975, WAPDA Grid System spread from Peshawar to Hyderabad, connecting all generating stations to
the load centers through 66 kV, 132 kV and 220 kV transmission lines.
PLC was formed, which provided direct dialing telephone communication with major power plants, grid
stations and Kot Lakhpat Load Dispatch Center.
In 1975, RCC was set up in Hyderabad to connect KESC Grid with WAPDA Grid to form the National Grid.
LDC Kot Lakhpat and RCC Hyderabad remained unautomated; PLC or conventional telephone
communication conveyed operating instructions to power plants and the grid stations, and the health of
the transmission network was assessed through frequency meters.
Modernization in early 1980s: with an increase in energy demand and generating capacity (addition of
Mangla and Tarbela hydro plants), WAPDA moved towards computerized control centers.
In 1991, NPCC and RCC North were established in Islamabad, and a RCC South at Jamshoro near
Hyderabad; halting load dispatch operations from Kot Lakhpat.
NPCC controlled generation plants and 500KV and 220KV transmission networks.
RCCs controlled 132 kV and 66 kV networks: network up to Multan under RCC North and beyond that
under RCC South.
75
Power Sector
Several facilities were provided under the upgraded project (Figure 7.1).
Figure 7.1. Facilities under the Upgraded Project
60 analogue channels (microwave) communication system_ connecting

power plants to 500 kV and 220 kV grid stations with NPCC and RCC
through RTUs
Automatic Generation Control
SCADA for online monitoring of generating units and grid stations
Stats Estimation
Contingencies Analysis
Training Simulator
7.2. TRANSMISSION CONSTRAINTS AND ECONOMIC MERIT ORDER
NTDC became a Public Limited Company on November 06, 1998, under the Companies
Ordinance 1984 (now Companies Act 2017); started its commercial operation in 1999
and got a license from NEPRA in 2002 for thirty years. NTDC transmission network is
spread all over the country except the area served by KE.
76
Power Sector
Table 7.1. Transmission Infrastructure Owns and Maintains by NTDC
TYPE Nos CAPACITY
Grid Stations 500/220/132 kV 18
Transformers 500/220 kV 46 25,500 MVA
Grid Stations 220/132 KV 48
Transmission Lines (circuits) 500 kV 51 7,238 km
Transmission Lines (circuits) 220 kV 159 11,281 km
HVDC Transmission Circuits ±660 kV 2 836 km
Source: NTDC Annual Report 2021
Figure 7.2. NPCC has been Performing as System Operator (SO); SO is Responsible for:
Short-term operational planning (one year ahead to real-time maintenance

schedule); coordination (generation & transmission), real-time operation, &
control, generation scheduling, ancillary services schedule
Ensures system's integrity, security and quality of supply, compliance with

emission requirements and suf�icient generation capacity to meet the
system demand
Evacuates power from generation plants to the distribution companies

through NTDC's EHV network
Dispatches load on economic dispatch criteria
77 77
Power Sector
Figure 7.3. Power System Managed by NTDC
23 WAPDA Hydel 6 GENCOs Thermal 33 IPPs Thermal

6 IPPs Hydel Power
Power Plants having Power Plants having Power Plants having
Plants having installed
installed capacity of installed capacity installed capacity
capacity of 485 MW.
9,389MW of 4,651 MW. of 17,309 MW
6 PAEC Nuclear 9 IPPs Bagasse 4 IPPs Solar Power 36 IPPs Wind Power
Power Plants having Power Plants having Plants having installed Plants having
installed capacity of installed capacity capacity of 400 MW installed capacity of
3,635 MW of 364 MW 1,835 MW
51 Transmission 2 HVDC 2 Convertor Stations

18 500 / 220 /132
Lines (circuits) at Transmission having 4,800 MVA
kV Grid Stations
500 kV Circuits at ±660 kV capacity
159 Transmission 1,310 Transmission

48 220/132 kV 1,016 Grid Stations
Lines (circuits) Lines (circuits) at
Grid Stations (132/11 kV)
at 220 kV 220 kV
The operation of the available power plants, as per the EMO, is critical to avoid high
electricity costs. In various instances, the operation of power plants violates EMO. In
FY2021 (as in the past), the transmission network could not transmit the available power
from ef�icient power plants to load centers. In FY2021, a veri�ied amount of Rs. 3.94
billion was payable to the WPPs on account of NPMV26. In FY2022, the total payment
to renewable plants on account of NPMV was Rs. 1.17 billion, and the �inancial impact due
to system constraints was Rs. 3,670 million (NEPRA State of Industry Report, 2022).
NTDC still requires a more extended period to �ix the existing constraints which are causing
the operation of power plants in violation of EMO. As reported in the NEPRA State of
Industry Report, 2021, due to an inadequate transmission system, NEPRA extended the
term of the generation license of some power plants despite the availability of unutilized
‘take or pay’ power generation capacity in the CPPA(G) System.
26 The intermittent nature power plants (wind) enjoy the priority dispatch condition. Non-evacuation of
available power from these plants makes them eligible for payment on account of Non-Project Missed Volume
(NPMV).
78 78
Power Sector
Box 7.1. Transmission Constraints
▪ Constraints like over-loading of transmission lines, insuf�icient transformation capacity

of power transformers, outages of transmission lines, etc., have been identi�ied as the
main reason for the under-utilization of ef�icient power plants.
▪ Not the �inancial resources, but non-professional boards, temporary CEOs, and the non-
availability of the national power policy are all responsible for transmission constraints.
▪ NTDC cannot fully deliver the needed power to the distribution companies and accept and
transmit ARE of the requisite level. NTDC is further not able to provide for the needed
transmission lines in the northern areas because of space constraints.
▪ It has not been able to upgrade its transmission voltage or induct newer technologies
like UHV transmission lines, SVCs, and storage batteries.
In foggy areas, replacement of all disc insulators with polymer type or application
of RTV coatings to reduce tripping of main lines in the winter season are held up/
delayed.
No re-designing of the system for installing shunt reactors to energize during the
low load period so that NPCC does not need to open 500kV lines to control high
voltages due to low system load. It also compromises system contingency/redu-
ndancy, ultimately causing system collapse.
There should be enough VAR absorption during the minimum load period. IPPs
are reluctant to do so as they don’t want their machines to run in highly excited
mode. NPCC cannot keep a check on those IPPs because real-time data is not
available; If real-time data is available, there is no penalty in PPAs for the IPPs if
they don’t support the system (provide/absorb VARs).
7.3. UPGRADATION OF NPCC

To upgrade the Load Dispatch System (LDS) at the NTDC, LDS Phase-II was signed in
201027. It included:
▪ Replacement of SCADA system in NPCC.
▪ Upgradation of telecommunication network, including installation of OPGW on

transmission lines.
▪ Installation of new digital RTUs at 500 kV and 220 kV grid stations and power
plants.
27 Similar system was installed by ESKRA of the Southern African Power Pool – a system supplying power to
15 countries of Southern Africa.
79 79
Power Sector
LDS Phase II also included software facilities comprising an operating system, software
maintenance tools and database management, as illustrated in Figure 7.4. LDS Phase-II
became functional in 2014 after achieving substantial completion; pending works were
addressed through a punch list.
Figure 7.4. Data Management Opportunities Included in LDS Phase-II
Load Forecast
Contingency
(short, medium
Analysis
& long term)
Optimum Reserve
Power Flow Monitoring
Online Load Generation

Flow Studies Scheduling
Online Unit
Economic Dispatch Commitment
Automatic Training
Generation Control Simulator
Weather
Stations in
the Field
In 2021, LDS Phase-III was executed (Figure 7.5)28 to facilitate the transition from a single-
buyer regime to a CTBCM. It is envisaged to accommodate various new RLNG, coal, and
renewable energy (solar, wind and small hydro) projects. The LDS system is expected to
help improve grid visibility and automation and enable seamless integration of renewables.
The project is scheduled to be implemented by FY2025. Its timely completion would

resolve some of the transmission constraints.
28 The contract has been given to a consortium comprising China Machinery Engineering Corporation
(CMEC) and Hitachi ABB Power Grids (formerly ABB Switzerland Ltd.). The total contract award cost is
equivalent to PKR 17,097 million.
80
Power Sector
Figure 7.5. LDS Phase-III Project
Upgradation
of Existing
set-up (SCADA /
EMS) at NPCC
Integration of
Existing (49+14) and
Secured Metering
Non-reporting (116)
Services Meters
RTUs. Interfacing of
Communication
Upcoming Power
Link
Plants and Grid
Stations
Revamping of Back-up Control

NTDC’s Telecom Centre at
System/ Facilities Jamshoro
7.4. SCADA AND THE DATA EXCHANGE PORTAL
Box 7.2. SCADA
▪ In power system operations and control, SCADA is the most effective tool to overview all
network elements regarding their operating state
▪ Data acquired through the SCADA system can be used for real-time operational decisions_
typically through EMS mathematical tools and ex-post trade settlements.
▪ In the absence of SCADA, real-time monitoring and the best decision-making through EMS
models is impossible; the optimality of decisions taken in real-time is compromised.
▪ The data collected through SCADA is an essential input for medium- and long-term
planning exercises. Otherwise, the quality of the operator’s decision will not be optimal.
81
Power Sector
▪ Currently, the settlement period is one month for the consumer / demand-side
billing in the power system. Relevant entities (NPCC, NTDC, DISCOs and CPPA
(G)) collect data for making a monthly settlement at the end of each month,
structure it, prepare settlement statements and billing / invoicing the power
sector entities.
▪ In the competitive market structure, e.g., CTBCM, the energy and capacity
settlement period for supply and demand-side participants will be one hour.
Availability of all relevant data sets on hourly resolution in a structured format
will be necessary.
▪ It can be achieved only through custom-built IT applications and software. The

data exchange portal is essential for operations and settlement of transitioned
electricity market.
Box 7.3. CTBCM and SCADA System
▪ CTBCM is based on the principles of transparency and reliability, which depend on the
quality of data related to all elements in the power market, e.g., generation, DISCO demand
and consumption, day ahead capacity submitted by IPPs, fuel mixes, weather-based
forecast for wind and solar power plants and many more.
▪ The success of CTBCM is possible with a fully functional SCADA system. By the time, SCADA
(LDS Phase-III) is matured, the data required by CTBCM will be provided by NTDC’s SMS
Project (using GSM, being an unreliable media and an obsolete methodology). Thus,
compromising both transparency and reliability.
SCADA and allied EMS_ are compulsory for optimal operational decision-making in Pakistan.
Even in a fully functional SCADA system, a data exchange portal_ for logging and maintaining
the operational decisions will still be needed. SCADA system can log if a unit is desynchronized
from the grid. If the unit is under forced outage, scheduled outage or is on standby, SCADA
cannot know the desynchronization. The system must log into some data portal.
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7.5. POWER BREAKDOWNS IN THE NTDC SYSTEM

▪ In Pakistan, the power system is spread over vast geographic areas; the chances
of faults and failures are high.
▪ Unpredictable defects and cascading events often lead to a blackout.
▪ As the energy demand grows, the power system operates close to the boundary
of steady-state stability, which can easily push the system into a dangerous
situation.
Figure 7.6. Causes of Power Blackouts
Transmission Line Tripping or Overloading
Control and Protection Systems Mal Operation
Lightning Strikes on Power Systems Equipment
Poor Maintenance
Human Fault
Voltage Collapse
Equipment Failure
Some recent tripping’s revealed shortcomings in the system. Generally, a blackout usually
starts as a single system failure, which can, in turn, lead to cascading failures. From the
time of the disturbance until the system collapses, the primary physical phenomena of
concern are mainly:
Transmission Lines Increase or Growing Low-

Generators
Overloading or Power System Frequency
Decrease of the Losing
Online Generator Voltage Collapse Oscillation of large
System Frequency Synchronism
Tripping Power Systems
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Power Sector
NEPRA inquiry of major breakdown (January 09, 2021) revealed serious lapses on the
part of NTDC, CPGCL and KE, which caused the breakdown and delayed power restoration.
During supply restoration, several IPPs could not synchronize their power plants with
the system within time.
Figure 7.7. Analysis
i. Imbalance in Generation and Non-availability

i. Transmission Constraints
of Spinning Reserve
Seasonal variation in generation makes the system extremely In summers, transmission constraints are experienced due to
vulnerable. In winter, hydel generation in the North is the non-availability of contingency and operation of transmission
nominal due to water shortage; power generation in the without N-I contingency.
South �lows to the North to meet the load requirement in
the North and Center. Hereafter any generation loss causes Major breakdowns occurred due to system disturbance in
the frequency to decline quickly from the tripping limits of 500 kV and 220 kV transmission lines (Table 7.2) and
generators; thus, cascade tripping of generators leads to a tripping in unstable power swing mode, which caused a
blackout. separation of the South and North Zones. The separation of
North caused cascade tripping, which resulted in an imbalance
AGC is available on major hydel plants Tarbela, Mangla and of power generation and connected load in both Zones. The
Ghazi Barotha. Due to the minimum load in winter on these power system in South Zone experienced overvoltage and
plants, the frequency control of the system becomes weak over frequency due to excessive generation compared to
the connected load. In North Zone, generation is less than
In some cases, the spinning reserve is also not maintained
connected load experienced under frequency situation;
as per the Grid Code. The reason is the minimum
result both zones plunged into darkness*.
availability of hydel generation and non-provision of tariff
for the open-cycle operation of the gas turbine to increase
generation immediately to remove the mismatch between
generation and load demand
*The power system in the South Zone experienced overvoltage and over frequency due to
excessive generation compared to the connected load. In the North Zone, generation is less
than connected load experienced under frequency situation; result both zones plunged into
darkness.
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Power Sector
Table 7.2. Major Power Breakdowns in FY 2018 to FY 2021
Date Details
August 1, 2018 Lahore_ tripping of 220 kV Bund Road Grid Station
August 12, 2018 Tripping of NTDC’s 500 kV and 220 kV transmission lines in the South:
High humidity & pollution affected power supply (PS) to KE from national grid
(NG) & generation from 1320 MW Port Qasim Power Plant and WPP in Jhimpir
& Gharo.
September 24, 2018 Same as above
October 2, 2018 Tripping of NTDC’s 500 kV and 220 kV transmission lines in the South:
High humidity & pollution affected PS to KE from NG & generation from 1320
MW Port Qasim Power Plant.
October 4, 2018 Same as above
October 25, 2018 Tripping of NTDC’s 500 kV and 220 kV transmission lines in the South:
High humidity, pollution & smog affected PS KE from NG & generation from
1,320 MW Port Qasim Power Plant.
November 12, 2018 Same as above
January 25, 2019 Tripping of 500/220 kV transmission lines in Guddu, Shikarpur, and Multan
region due to extreme weather caused by dense fog/smog and
pollution/contaminated layers on insulators caused by a variety of sources,
i.e., sea, salt, industries.
It also caused tripping of HUBCO, Port Qasim, and Guddu Power Plants,
resulting in a power failure to large parts of Sindh (NTDC & KE networks) &
Baluchistan.
January 09, 2021 Tripping of 500 kV and 220 kV transmission lines due to faulty breaker at
Guddu; isolation of system in North and South regions_ complete system
collapsed (country plunged into darkness) because of cascaded tripping.
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Power Sector
7.6. DELAYS IN SYSTEM RESTORATION AFTER BLACKOUTS: REASONS &

SOLUTIONS
REASONS SOLUTIONS
Non-availability of Black Start Facility29 : Power plants Availability of a Black Start Facility at gas turbine
are without Black Start Facility except Tarbela, power stations, with an approved tariff on open cycle
Mangla, and Warsak in the North and KAPCO in the operation, can facilitate the rapid restoration of the
Center. system.
Noncompliance of Power Plants: In the restoration Power plants need to be made more compliant to
process, system parameters frequency and voltage vary respond quickly.
abnormally outside the normal limits in the initial
stage of restoration. Therefore, power plants hesitate to
participate in the restoration process, causing delays.
Improper Communication System: Absence of proper PLC, mobile phone, wireless communication system,
and well-maintained communication facilities causes a and landline are necessary for �ield formations and
delay in restoration. operator control room staff.
Non-availability of Trained Staff: Training simulators Trained staff must be readily available in the system
are not available; therefore, no drills occur. Staff with operator control room, power stations and grid
minimal experience restore the system, causing delay. stations. The team should be trained_ by conducting
drills regarding restoring the system on a training
simulator.
Non availability of Synchronization Devices All key grid stations and power stations must have
synchronizing devices, i.e., Synchro Scope and
Synchro Check Relays. When required for coupling
the islands/systems, these should be in working
conditions.
Improper SCADA System: The SCADA system is Fully operational SCADA system should be made
available on primary power systems and not on available to restore the whole power system quickly.
secondary systems; many power plants and grid
stations are not integrated with SO control rooms. Oral
communication causes a delay.
29 Black start is the ability of generation to restart parts of the power system to recover from a blackout.
This entails isolated power stations being started individually and gradually reconnected to form an
interconnected system again. https://www.nrel.gov.
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Power Sector
Way Forward
NTDC must comply with industry standards and uniform codes of conduct on the safety,
reliability, stability, integrated operability, and ef�iciency of the whole or a material part
of the electric power system. The ability of power systems to ensure a continuous supply
of electricity to customers in the event of a disturbance is crucial.
▪ Comprehensive grid studies for steady-state and transient stability and reliability,
considering the renewables and future energy plans up to 2040, are critical.
▪ Transmission system issues re�lect a lack of integrated planning. Immediate

measures are required to address the inadequacies of the transmission network.
▪ Timely completion of the LDS phase-III projects grid strengthening, and
modernization is signi�icant.
▪ Usually, machinery and equipment take priority in cost allocations. Prioritize

capacity building and training of staff; capacity building of system operation
staff at NPCC is vital.
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Power Sector
8. ASSET MANAGEMENT AND PROCUREMENT IN POWER SECTOR
The critical issues in the procurement and assets management processes in Pakistan's
power sector stem from the weak regulatory and operational framework. Organizational
structures are less oriented toward delivery; lack procedures, techniques, resources,
and most importantly, the inconsonance of rules and regulations at different levels.
8.1. POWER SECTOR PROCUREMENT PROCESS AND CHALLENGES
▪ The procurement in the power sector is mainly through NTDC. In FY2021,

around Rs 56 billion was spent under the heading.
▪ The procurement of Rs 60 million and above is by the MP&M department in

NTDC.
▪ Federal Public Procurement Regulatory Authority (PPRA) Rules 2004 (amended

to date) are followed30.
Some of the signi�icant power sector procurement and supply chain related matters,
which require immediate attention for bringing positive developments, are discussed in
Table 8.1.
30 If �inancing is done by the International Financial Institutions (IFIs), their guidelines and regulations
are followed. PPRA Rule 5 stipulates that in case of con�lict between PPRA and IFIs guidelines, the latter
shall prevail to the extent of such con�lict. Pakistan has nearly always been on the maps of various IFIs.
They choose projects as per their preference.
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Power Sector
Table 8.1. Power Procurement Challenges
Unrealistic Project ● Functional offices prepare PC-1s: they work in silos, with little
Charters knowledge of PSDP, MLDA programs, SDGs etc.
● Project concept papers usually lack information on ground realities,
including complications associated with financing arrangements,
acquiring land, etc.
● Unrealistic Timelines in PC-1, time get lapsed even before commencing
the procurement process (most of the time)
● Delays even after the approval of PC-1.
Financing Uncertainty ● Projects are approved without securing �inancing (in the majority of
cases).
The IFIs select the project after the approval of PC-1 (at least from CDWP).
Corporate’s Priority ● Mechanisms/SOPs for determining the priority for procurement/

projects do not usually exist.
● Work is executed urgently as a �ire�ight rather than a proactive
requirement and project management process.
Absence of Dedicated ● Absolute responsibility in the form of a designated project

Project Manager manager/process owner is absent; resultantly, lack of coordination
leads to inefficiency in managing scopes and schedules.
Need ● No mechanism exists.

Assessment/Inventory
● Operational requirements are rarely consolidated and translated into
Planning
inventory and management plans.
● Most entities do not procure or publish their annual procurement plans,
indicating their lack of background work and planning.
● Plans are kept hidden due to a lack of certainty of needed �inancial
resources and lackluster human behavior.
Non-uniformity of ● Inconsistency (regarding document types, evaluation/quali�ication

Bidding Documents criteria & contract mode/type etc.) in the procurement documents.
It creates confusion for the market/industry participants and doubts
about process transparency.
Non-consideration of ● Pre-market surveys are often not conducted; bidders' alliances and
Market Conditions suggestions are not obtained; documents are not improved from time to
time.
● More attention to compliance matters and transparency requirements
while compromising the critical purpose of obtaining the best product
and value for money.
Primarily quality-oriented firms refrain from participation, leading to
severe complications/issues at a later stage, i.e., in the evaluation, award
and contract management process and at a cost of quality work.
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Power Sector
Absence of a Pre- ● Pre-qualification mechanism is entirely missing due to stringent

qualification Regime regulatory requirements in the public sector.
● No permanent process, pre-qualification is allowed on a project-to-
project basis; it becomes extremely cumbersome.
Non-Standardization of ● Standard procurement documents do not exist.

Documents and
● Where there are standardized documents, they are with strict
Disregard of Tailoring
indigenous instructions to follow, and not tailored enough to attract
Needs
competition.
Simple procurement is hurt when the rigorous process of some standard
document is used.
Conflicts between PEC ● Confusion for public sector organizations regarding which standard,
and PPRA practices, or procedures to follow: PPRA or PEC.
The confusion is hampering the development of best practices and
organizational processes.
Additionally, PEC uses a very obsolete version of the FIDIC Conditions of
Contract issued in 1987 rather than a version of 1999 or 2017.
Focus on Cost & not ● Misunderstanding in companies that procurement is all about
Quality achieving least cost. The result is, vendors attempt to meet minimum
cost requirements to win contracts, compromising quality. It led to an
ouster of European manufacturers/ suppliers from the Pakistani
market.
E.g., NTDC replaced its earlier 2nd and 3rd generation equipment
with a newly painted version of the same generation; in 15 years,
NTDC has regressed_ into an outmoded transmission company.
Focus should be on the quality of the product in the evaluation criteria to
bring value for money.
Delays in Processes ● Engineering departments evaluate bids, resulting in extreme

workload and delays.
● Evaluation with strictest interpretations, delays ongoing
procurements, creates complications in the award process, and
discourages reputed bidders/�irms.
A project procurement timeline reveals that from the preparation of PC-1 to
the project's actual start, the time involved is at least three times more than
the stipulated time.
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Power Sector
Lack of Change ● Bureaucratic norms, procedures and the continuous interference of

Culture accountability forums hamper the reform process.
● With time, procurement processes have become more bureaucratic_
even a most quali�ied leader becomes non-responsive to minor
deviations.
● No significant progress in implementing Enterprise Resource Planning
systems for procurements or in e-procurement initiatives.
Outdated Specifications ● Power companies lagged in adopting innovative solutions (digital

and Type Testing protections, insulation coordination, etc.).
Requirements
● No change in specifications; type test requirements are also not
standardized.
Inventory Turnover ● No SOPs exist for determining minimum inventories, inventory

turnover, trigger points, lead times, etc., creating complications. Often,
disproportionate procurements of inventory, i.e., unnecessary buildup
or lack of critical stocks.
Disposal of Inventory ● Inventory disposal and the maintenance of existing stocks are chronic
challenges.
● Un-useable inventory remains pending for a long time creating a burden
for the organization in terms of stuck financial capital and inventory
keeping costs.
Resource Constraints ● Acute shortage of skilled professionals/experts in procurements and

overall project management frameworks.
● Over time, necessary expertise has not been developed in the relevant
�ield due to a lack of incentives to pursue a speci�ic area.
● Lack of skilled staff_ planning, preparing the necessary documents,
tendering, and contracting are all taken up super�icially.
● Other functional departments, part of the procurement cycle, also suffer
from human resource shortages, leading to delays and complications.
Way Forward
▪ Procurement of equipment and services (consulting and non-consulting)

consume almost the entire development budget of DISCOs & NTDC. Solving
underlying issues are critical for progressive development of continuously
evolving processes.
▪ Coordination between the functional departments, deputation of dedicated

project managers, improving project management practices, developing PMOs
and SOPs etc., is a starting point toward the reform process.
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Power Sector
Innovative thinking, proactive problem solving, and an ef�icient and effective

procurement process can turnaround power sector entities' performance.
8.2. LACK OF ASSET MANAGEMENT SYSTEM IN NTDC
Asset Management is a set of systematic and coordinated activities and practices that
improve the performance and quality of the electricity grid. It ensures that the grid operator
manages its critical infrastructure cost-effectively by optimally controlling the assets over
their life cycle.
Box 8.1. Global Asset Management System
▪ Over the past decade, power transmission and electricity utilities worldwide have undergone
a signi�icant business and regulatory change. Most have embraced competition and
commercialization concepts.
▪ Some government-owned companies have moved towards corporatization and full privatization.
▪ The focus has shifted from engineering excellence toward commercial performance; the term
“Asset Management” has become the new business ideology for these companies.
NTDC has its Asset Management Department, but it does not conform to international
standards in the true sense31. It is inef�icient and ineffective for several reasons, as listed
in Table 8.2.
31 Huge loss of power transformers and related equipment in recent years.
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Power Sector
Table 8.2. Reasons behind Weak Asset Management
Poor Preventive & SOP formulated by the technical services group of NTDC for preventive
Condition Based and condition-based maintenance are not followed.
Maintenance
The health of the costly electrical assets deteriorates and ultimately fails.
Corrective mechanism does come into play but after causing a huge cost
imapct.
No Proper Asset No complete database or adequately maintained registers of_ previous test
Management results and history of equipment for evaluation, interpretation of test results,
Database and formulation of run-refurbish-replacement strategies.
Shortage of Signi�icant shortage of skilled and trained crew, especially for the
Skilled/Trained maintenance of transmission lines, gas insulated substation, major switchyard
Manpower equipment like transformers, shunt reactors, etc.
Repairing work of damaged equipment like transformers is outsourced, which
causes substantial financial loss.
Shortage of Shortage of major T&P and testing sets for switchyard equipment testing, and
Maintenance Tools & live line/deadline maintenance.
Plants (T&P) and
Testing sets are used on a pool basis; sometimes, some major maintenance
Testing Sets
tests are skipped.
Insufficient Logistics Insufficient logistic support (e.g., cranes, trucks, and live line washing units)
Support required to attend major breakdowns in grid stations and transmission lines
in diversely spread and huge NTDC transmission network delays the
rehabilitation of the system.
Geographical In enterprise asset management, GIS provide a wealth of information; NTDC

Information System lags in this area despite colossal capital investment in its network.
(GIS)
Non-Availability of Shutdowns for preventive maintenance have suffered due to the shortage of
Shutdowns power supply and to ensure power system continuity in essential areas.
When shutdown is allowed, the time is insufficient to complete proper
maintenance work.
Unplanned Asset management is dependent on procurement to acquire and dispose of

Procurement & assets and obtain spares and services to improve availability; NTDC, with no
Inventory Issues proper mechanism to assess requirements, leads to disproportionate
procurements of inventory.
No Expert/ Intelligent To protect signi�icant assets (e.g., power transformers), there is a need for
Systems expert systems to continuously monitor the equipment's health like online
Dissolved Gas Analysis (DGA) and online Partial Discharge to avoid any
unforeseen events, otherwise, it damage equipment before its age.
System Constraints Major blackouts in the last decade were mainly due to the non-redressal of
Causing Collapse system constraints (details in Chapter 7).
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Power Sector
Action Points
▪ Intelligent Power Network Stability systems with strong telecommunication media

should be installed to replace the under /over frequency schemes.
▪ Major equipment replacement work, extension requirements, and rehabilitation

works need to be reviewed and prioritized in the light of power system planning
studies, substation and transmission line constraints and system stability.
▪ Re-design transmission systems; the ring-main systems (missing in current

system) allow shutdowns on affected areas without disrupting the whole system.
▪ For a well-developed asset management framework, there is a need to understand

and include available techniques in the strategic planning of the power industry.
(Organizations like ISO, BSI, EPRI and CIGRE have developed guidelines for
asset management in the power industry)
▪ A progressive development, i.e., continuously evolving processes, are required to

develop the asset management system.
▪ Both policymakers and the regulator should address the critical issue of asset
management meticulously_ a short, mid, and long-term asset management plan is
needed.
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Power Sector
9. POWER PLANNING: FAILURES OF THE LAST THREE DECADES
The people, process, and technology drive the enterprise forward. In Pakistan, due to
the skewed planning process and the lack of involvement of the professionals in the
decision-making process, power sector organizations have become insensitive to the
importance of the planning process. The problem is not where to go but how
to get there.
9.1. INTRODUCTION
After the appropriate policy instruments, the �irst prerequisite for keeping the lights
on across the country under all conditions is prudent system planning. It involves
considerable time, capital, and potentially severe economic risks for the electricity
utility and the economy. Under power sector reforms in the late nineties, NTDC was
mandated to plan power systems for the whole country, excluding Karachi and its
adjoining areas under KE.
Our planning strategies in the past have focused on expanding generation capacity,
with little attention to improving the transmission capacity, energy mix, energy
ef�iciency and distribution planning. Without any doubt, planning for increased
electricity generation capacity is a vital component of electricity planning; other
elements are equally important.
9.2. DISTRIBUTION PLANNING: A MISSING LINK
Distribution Planning Under WAPDA
WAPDA set up departments for power planning, design & standards, contracting, constructing
& operating the power sector. Plans were developed to expand the power system in the
minimum possible time and expenditures. Standards and design departments probed
international standards; then stretched the system while assuring the safety of both men
and material.
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Power Sector
▪ The standards were speci�ied to replace copper with aluminum as the preferred
metal for the conductors and cables. Various protection schemes were also
tweaked on the LT and the HT sides; the distribution system was designed to
operate with high tension protection ef�iciently.
▪ Distribution engineers (under the USAID program) were trained from the
American Electric Power (AEP), United States. These professionals were provided
with the latest distribution controls and allied equipment.
WAPDA was able to craft and issue several: product descriptions (designs), speci�ications
including the standard design instructions, technical instructions, and standard operating
procedures32. Planning resulted in fast-tracked development and an unprecedented expansion
of the modern distribution circuits in the country.
Distribution Downfall
The gains started dwindling by the mid-1980s, with WAPDA leaning �irst towards transmission
and later to generation wings. Administrators (not even managers) were posted as an
alternative to engineers or engineering managers in the distribution wing. The distribution
system slowly became outdated.
▪ Same distribution voltage as evidenced in the early 1960s.

▪ Distribution transformers (including their size and capacities) remained stuck
in the 1910s design and con�iguration.
▪ The energy meters retained their original Ferranti’s principle until the
introduction of electronic meters in the early 1990s.
▪ The electronic or digital meters retain their physical parameters as earlier
electro-mechanical versions.
In 1990, the local industry was encouraged to enter the engineering domain.
▪ The earlier technology transfer stagnated, and the locals took over from the
migrating international manufacturers. Even the blatant assemblers were
accorded the label of original manufacturers.
▪ Clumsy installations block the urban landscape.
32 These documents numbered hundreds and could answer any call for utility-related works. The army
management of WAPDA (during 1998-2004) acknowledged that the procedures in WAPDA are so detailed
that even the Armed Forces cannot match.
96 95
Power Sector
▪ Underground distribution installations in some parts of major cities are an

exception.
Consequently,
▪ LT lines remained without the system's modern clamps/conductors / T-off

hardware.
▪ Instead of adhering to technical instructions where 19 speci�ic items are speci�ied

for single-phase connection, only the service cable and the energy meter are
issued and installed.
Because of the below-par design planning of the distribution systems, the supply to
customers is sub-standard_ bouts of low and high voltages, electrocution and other
accidents, and millions of interruptions all over the country.
Why is Distribution Planning not a Priority?
From 1994 to 1998, the �inancial viability of WAPDA became dubious due to the induction
of an IPP, HUBCO, and other related obligations. With de�iciency on the �inancial and
technical fronts_ the distribution system planning lost its priority. Even after the corpo-
ratization of WAPDA entities, no distribution planning could be undertaken (from 2011
to 2018); the GOP focused on adding generation capacity.
From 2018 onwards, with the help of multilateral donor agencies, DISCOs set up their
planning and development of�ices. At present, some rudimentary services are provided
by these of�ices.
▪ Because of the unnecessary interference of the PPRA, the DISCOs have always
avoided any private contractual help for planning purposes_ which is funda-
mental for apt distribution design modules.
▪ P&D departments in DISCOs are more like post of�ices, and no actual planning
takes place.
▪ No effort/ plan to improve the distribution systems to face new realities and
the ongoing economic crunch
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Power Sector
The same old 1960s design carries on, but with more dilution and deterioration.
9.3. ISSUES IN PLANNING PROCESS AT THE NTDC
Box 9.1. Planning Process Fundamentals
▪ The planning process begins with the load demand forecast using econometric/ statistical
tools for the plan period.
▪ Based on the load forecast, a generation plan is formulated. A generation plan is an optimization
exercise of projects with varying sizes, types, technology, location, and energy source to meet
the load forecast.
▪ Plan also proposes alternate options/ possible actions through sensitivity analysis to take
care of any variation in the study assumptions.
▪ A high voltage transmission system is planned primarily to evacuate the electric power
generated from various sources located in different parts of the country. It is developed
through a diverse and complex technical analysis of the power system.
▪ Transmission planning and generation planning are performed iteratively to achieve an
optimal output due to the dynamic nature of the power system.
▪ Technical analysis is followed by commercial analysis, which includes �inancial and economic
aspects to �inalize the mode of investment for the transmission projects.
Load Forecast
Generation Plan
Transmission Plan
Resource Plan
In the last three decades, the lack of comprehensive planning allowed non-competitive
generation projects to be commissioned on a quid pro quo basis.
In 2005, NEPRA approved a Grid Code to govern the development, planning and operation of
the National Electricity Grid. The Grid Code had partially de�ined the planning process for
Pakistan's power sector.
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Power Sector
However, the intent and implementation of the Planning Code, a sub-code of the Grid Code,
were miles apart. The Planning Code of the Grid Code establishes the planning process
to be followed to plan the power system. Unfortunately, it was only recognized and
complied with fourteen years after the promulgation of the Grid Code through the IGCEP
2040.
Box 9.2. Power Sector Expansion Plans
▪ Liefticnk Report 1967

▪ RESPAK Model 1988
▪ Energy and Nuclear power Planning Study for Pakistan (ENPP 1994)
▪ National Power Plan (NPP 1994-2018)
▪ Energy Security Action Plan (2005-2030)
▪ Pakistan Integrated Energy Model (Pak-IEM) 2007
▪ National Power System Expansion Plan (NPSEP 2011-2030)
▪ Least Cost Plan (LCP 2016-2035)
▪ Indicative Generation Capacity Expansion Plan (IGCEP) 2040.
▪ Indicative Generation Capacity Expansion Plan (IGCEP) 2047.
Box 9.3. Grid Code 2005
The Grid Code 2005 states that each year the NTDC shall prepare and deliver to NEPRA a Ten
-Year Indicative Generation Capacity Expansion Plan (IGCEP) or NTDC Plan covering a 0-to-10
-year timeframe. The NTDC plan shall be based on a twenty-year Load Demand and Energy
Forecast. It shall be prepared according to a Loss of Load probability (LOLP) methodology
established under this Grid Code and NEPRA Transmission Performance Standards rules.
The NTDC Plan shall be used as an input to prepare NTDC’s Transmission Expansion Plan (TSEP).
A detailed Transmission Investment Plan shall be prepared based on the NTDC Twenty-Year
Load Forecast, Indicative Generation Capacity Expansion Plan (IGCEP or NTDC Plan). At the
same time, the Transmission System Expansion Plan (TSEP) will also be based on Annual System
Reliability Assessment and Improvement Report (ASRAIR).
In the past, several generation expansions plans, with input and assistance from foreign
and local consultants, have been framed (Box 9.2). In most of these plans and load demand
forecasting studies by NTDC:
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Power Sector
▪ Planning for generation expansion was based only on peak demand forecast,
which is sometimes misleading.
▪ There was a lack of spatial forecasting in most of these reports.
▪ Planning was done for the existing consumers, not those who are unserved or
underserved.
That is why investments to increase generation capacity are separate from equivalent
investments in downstream transmission & distribution infrastructure. The IGCEP 2021
was the �irst-ever generation plan approved by the regulator (NEPRA). NEPRA directed
NTDC to submit the TSEP for approval with the next iteration of the IGCEP. However, the
draft of the next IGCEP 2022 is submitted to NEPRA for approval but work on TSEP is
still underway. Delays in TSEP re�lect the working capacity at the NTDC. IGCEP 2021 could
have been more �lawless, and so is the draft IGCEP 2022.
9.4. FAILURE OF LAST THREE DECADES
9.4. FAILURE OF LAST THREE DECADES
▪ During the last three decades, power system planning and implementation of the planning
process have not remained the preferred approach.
▪ Since the early 1990s, Pakistan's capital-intensive power sector has experienced a tumultuous
and unsustainable journey, ignoring research-based planning input for policy making.
▪ Generous terms/ incentives were offered to investors in the 1994 power policy without
paying any attention to the planning or economic and �inancial analysis performed by the
engineers of WAPDA through the National Power Plan 1994.
▪ A similar trend was followed in the subsequent power policies of 2002, 2006 and 2013
2013 saw the CPEC entry into Pakistan. The GOP introduced another power policy in 2015*
to combat severe load shedding, reduce constantly rising circular debt, and attract CPEC
investment in the power sector, followed by the promulgation of the Alternative and Renewable
▪ Energy Policy 2019.
▪ Established in 1958, WAPDA quickly laid the �irm foundation of the present power sector
infrastructure. The early nineties saw the potential beginning of ignoring research-based
planning input for policymaking.
In pursuit of a sustainable sector to supply reliable electricity at affordable prices to the consumers,
all interventions have made the power sector of Pakistan an unbridled hydra-headed monster -
complex and uncontrollable rather than sustainable.
Power planning is undertaken in a fragmented way by the NTDC, CPPA(G)_ with its control
through Power Acquisition Request (PAR), the Planning Commission on the Integrated Energy
Plan, and now by the PP&MC.
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Power Sector
Table 9.1. Factors Affecting Power System Planning
FACTORS COMMENTS & RECOMMENDATIONS
Lack of Processes To build and sustain a compliance culture to achieve the objectives of the prevailing policies and the
regulatory framework, power companies must adopt a 5-step strategy; the importance of IT cannot
be underemphasized: Develop step-by-step processes indicating related parameters, responsibility,
sequence, etc.; Document the developed processes along with process maps; Communicate among the
concerned professionals; Implement the whole program, including the procedures and processes, in a
received, updating policies/regulatory framework for all future iterations.
It must be an ongoing process to ensure continuous improvement
Brain Drain In 1994, a planning (experts) team was established comprising Ph.Ds. from different disciplines of the
power sector to work alongside a team of international experts to develop the National Power Plan.
However, public sector culture and weak remuneration structures could not sustain the engineers'
knowledge base and expertise.
● NTDC management must get sensitized to this challenge and hire quali�ied professionals to
strengthen power system planning.
● Monetary incentives and appreciation (additional marks in Performance Evaluation Reports)
would help
Insuf�icient Capacity & Many positions are lying vacant for a long time due to the ban on new hiring & priority to other
Lack of Formal Capacity- departments, hindering performance. Limited available staff get overburdened and lackluster and look
building Opportunities for transfers to other departments.
At NTDC, except for transmission planning, there are no formal training/capacity-building programs
for load forecast, generation planning, and resource planning.
● Undertake regular training programs and other networking initiatives based on each
planning component.
● Capacity building at the individual as well as at the institutional level.
● Foreign training should be organized in a well-planned manner focusing on relevance,
broader participation, and impact.
Posting of Professionals in Professionals (even in senior positions) with no aptitude for planning are tasked to work in the
Planning Department as planning department on a short and long-term basis.
Transit Lounge
● NTDC management must be sensitized to the strategic importance of the planning
process and the power system planning department.
Obsolete Software and Obsolete software has remained in use for critical applications such as medium-term demand forecast
Delayed Digitalization and generation optimization.
Lack of automation of the historical data (in NTDC custody) and digitalization of input data for demand
forecast, generation optimization and resource planning has been the primary cause of inconsistent
reporting/information.
Although PLEXOS and PSR Suite have been procured to replace WASP*, it is still insuf�icient. More needs
to be done to digitize input data for better demand forecast, generation optimization and resource
planning.
No R&D Activities ▪ NTDC must incorporate R&D activities through an exclusive and cohesive program to contest
prevailing challenges (i.e., copy-paste culture).
Average Performance ▪ Proactive compliance with the regulatory framework (Grid Code 2005, Performance Standards,
Concerning Regulatory etc.) can undoubtedly improve precision and the planning function of NTDC.
Compliance
* Apart from other limitations, WASP could not distinguish renewable energy as a unique source.
101
Power Sector
Key Takeaways
With a team of hardcore engineering experts and distribution system planning, an exemplary
electricity distribution system was developed in the early years of WAPDA. In our planning
strategies, the focus has remained on the generation capacities, ignoring the distribution
sector.
In NTDC, the need for planning and compliance of planning with data-driven decisions
has been realized in recent years33. The signi�icance of data-driven and analytical recom-
mendations from professional/ technical experts is increasingly appreciated. IGCEP 2021
(although not �lawless) approval is the �irst step toward unbiased and analytical decision-
making. Yet, the damage done in the past is not easy to revert in the short term.
But no progress on the distribution and transmission side. DISCOs are responsible for
assuring the �inancial viability of the whole power sector. The missing distribution
planning and the resultant non-up gradation of design features, standards, etc., do not
allow the DISCOs to achieve their goals.
Our policymakers' lack of informed long-term vision has cost Pakistan dearly. Fragmented
planning at the individual departments; the problem is not where to go but no clarity on
how to get there
Moving Forward
▪ Fragmentation in power planning must change and go over to the Planning

Commission. In the past, the broad energy sector objectives were stipulated in
Pakistan's �ive-year plans (prepared by the Planning Commission) in a well-
conceived and coordinated manner.
▪ These plans should be prepared after systematic consultations with all stake-
holders, including deliberations in Parliament and the Council of Common
Interests (CCI).
▪ Planning should be like a process completed with a detailed implementation
plan and prepared after in-depth research by local people and not by donor
agencies.
33 The decision-makers and international donor agencies are keen on investing in planning departments -
enhancing the capability of the engineers and professionals, equipping them with state-of-the-art tools and
software and empowering them to participate in the decision-making process.
102
Power Sector
▪ An integrated and coordinated power sector planning is required. This approach

must include accurately forecasting demand, adding generation capacity,
improving and expanding transmission and distribution infrastructure, increasing
ef�iciency, bringing costs down, and ensuring sustainability.
▪ Policymakers/ planners should understand the complex economic, political,

and environmental interrelations and energy systems' uncertainties. Coordination
should not be limited to the energy sector but serious consultation with other
sectors.
▪ It is time that NTDC builds its professional and institutional capacity, launches
its formal R&D component, and encourages its professionals to contribute to
this proactively. The planning and development department in DISCOs must
be revitalized by employing professionals to provide substantial input in the
integrated planning framework at the Planning Commission.
103
Power Sector
10. REGULATORY AFFAIRS AND CONSUMER-END TARIFF DESIGN
The tariff structure in Pakistan is not based on regional and consumer-speci�ic long-run
marginal costs. It is used as an instrument to achieve political and socio-economic
objectives. Besides creating �inancial dif�iculties for the government, the tariff structure
also generates inef�iciencies in the system and misleads investment decisions in the
supply system.
10.1. ESTABLISHMENT OF NEPRA
The National Electric Power Regulatory Authority (NEPRA) was established under Section
3 of the Regulation of Generation, Transmission and Distribution of Electric Power Act,
1997 (NEPRA Act No. XL 1997) to regulate the provision of electric power services in
Pakistan.
▪ The objective was to improve the ef�iciency and availability of electric power
services while equally safeguarding the interests of consumers, investors, and
operators; and to promote competition and deregulate power sector activities
where competition exists.
With the foundation of NEPRA, all regulatory powers of WAPDA were transferred to
NEPRA. To create a legal basis for developing a competitive electricity market, the NEPRA
Act was amended in 2018.
Box 10.1. NEPRA Major Regulatory Obligations under NEPRA

Act No. XL 1997
▪ Grant of licenses, approval of power acquisition programmes.

▪ Determination of tariff, terms and conditions and rates.
▪ Prescription and enforcement of quality-of-service standards, approval of operating codes
and investment standards.
▪ Industry structure/privatisation including the transition towards a competitive market
where feasible.
▪ Consumer rights and obligations_ complaint redressal.
104
Power Sector
Under NEPRA, except for tariff determination and the grant of licenses, the power sector
operated without the requisite grid & distribution codes, consumer service rules, perfo-
rmance standards, commercial procedures, and other regulatory prerequisites for many
years34 . In those years, the power sector was operated under WAPDA’s detailed regul-
ations_ inclusive of technical speci�ications, procedures, and related handouts.
NEPRA accepted the tariff structuring processes of WAPDA only temporarily. NEPRA
announced Tariff Standards and Procedure Rules in 1998, to deliver separate tariffs for
the generating plants (both in the public and private domain), NTDC, and distribution
companies.
All the remaining requisite rules, regulations, and technical details were announced after
a few years. Details of regulatory framework at NEPRA to date, are listed in Appendix Fa.
In terms of performance, NEPRA has failed to perform its duties effectively as an exclusive
power sector regulator over the years (Box 10.2).
10.2. TARIFF DETERMINATION
▪ Under Section 7 (3) of the NEPRA Act, 1997, NEPRA has the power to determine
tariff rates/ charges and other terms and conditions for supplying electric
power services by generation, transmission, and distribution companies.
NEPRA Tariff Standards and Procedure Rules (1998) provide guidelines for
process and parameters for setting tariffs
34 In its early years, NEPRA adapted procedures from its counterpart in India and the United States. The
US has distinct state regulators_ all-powerful, over-seeing sectoral operations and has assured the needed
balance between the utilities and their consumer base.
105 104
Power Sector
Figure 10.1. Tariff Structure
Capacity Charges
Generation Energy Charges
- Use of System Charges (�ixed cost) determined annually

Transmission - Pool generation cost (�ixed and variable cost) transfer pricing
mechanism for DISCOs including KE to the extent of 650 MW
(Power Purchase Charge for DISCOs)
- Distribution Margin
- Power Purchase Price (PPP) charged to DISCOs under the transfer
price methodology for approval by NEPRA for recovery of pool
Distribution
generation costs charged to DISCOs by NTDC / CPPA-G
- T &D losses
- Prior Year Adjustments
106
Power Sector
Box 10.2 NEPRA Performance
▪ The overall de jure performance at NEPRA is better than the de facto performance.
▪ A regulatory system with several necessary qualities for the power sector is put in place
however, a signi�icantly poor regulatory performance in practice.
▪ The regulatory reform required to transition towards a competitive market has historically
been resisted in Pakistan. NEPRA is equally to be blamed for not developing market
competition over the years. NEPRA, an autonomous organization (by law), didn’t make
serious efforts to improve regulatory and operational infrastructure in the power sector.
▪ NEPRA has been unsuccessful in developing and pursuing a regulatory framework to
guarantee reliable, ef�icient, and affordable electricity.
▪ Effective regulation creates a balance in the interests of all stakeholders. When investors
achieve fair returns, consumers receive quality service, and governments are not allowed
political exploitation. NEPRA failed to create this balance.
▪ No effort on the part of NEPRA to revise consumer tariff methodology to make it competitive
and affordable for the end-consumers.
▪ Privatization was not directly the function or responsibility of NEPRA, not even after the
amended Act 2018. But under law, NEPRA was supposed to facilitate the process to bring
ef�iciency in the sector and help ensure competition where feasible. The privatization
process remained slow. KE was privatized in 2005 but is still treated as a state-owned
utility by the regulator, the same rules are applied, and it operates in a regulated environment.
▪ NEPRA adopted an inconsistent approach in approving the PPAs; the public sector projects
were considered to operate without PPA, or their PPAs were not per standard documents.
▪ Licenses were granted without observing the criteria in the rules, regulations, and prudent
utility practices.
▪ Monitoring the licensees (compliance and performance) against standards and prudent
utility practice was not carried out.
▪ Provisions of grid code, distribution code, commercial code, tariff guidelines, consumer
service manual etc., were largely ignored in regulating the power sector. The enforcement
mechanism remained fragile at NEPRA.
▪ Determinations of the Authority are general and without due detailed analyses.
▪ The generation licenses were granted without considering the actual demand in the system,
fuel mix and availability, �inancial cost of interconnections, etc.; it impacted the sector
enormously.
▪ Modi�ications in generation licenses, especially of GENCOs, were made without considering
their inef�iciencies and adverse impact on the sector.
▪ Delays were observed in tariff determinations, power acquisition requests, review motions,
etc.
▪ NEPRA’s job as a regulator was to resolve all the power sector problems, including system
losses, rising costs, high tariffs, and generation capacity challenges. Again, the outcome of
regulatory oversight_ the CD, emerged for the �irst time in 2006. Since then, it has been
there and rising. NEPRA has not done anything to control this debt from rising. Increasing
costs of generation, sector inef�iciencies, anomalies in tariff methods, and delays in tariff
determinations are responsible for the CD. If NEPRA had played an effective role, the power
sector scenario could have differed.
▪ The regulator makes no serious efforts to improve its overall capacity.
Source: (Malik, 2022c)
107
Power Sector
On receipt of tariff petition, the process is followed as elaborated in Appendix Fb. Tariff
determined by NEPRA is forwarded to the federal government under Section 31(4) of the
NEPRA Act for noti�ication in the of�icial gazette
Figure 10.2. NEPRA Tariff Regimes
Generation Transmission Distribution
▪Cost-plus
▪Up-front
▪Competitive Bidding ▪Cost-plus ▪Revenue cap
▪Interim Power ▪Competitive Bidding ▪Price Cap
Procurement
Regulation
Anomalies in Tariff Determination
▪ Over the years, the regulator has not allowed prudent cost (Figure 10.3). Tariff
determinations were made, but the laid down criteria for determining tariffs
was not followed strictly.
▪ While determining the tariffs, the projects in the public sector were treated
differently and allowed to pass on their inef�iciencies to consumers.
▪ In the generation tariff, the BOOT tariff was applied to the BOO regime_ a
payment of 80 percent plant cost in the �irst 10-15 years. The 15-18 percent
returns on equity with return in dollars despite substantial cost incurred in
Pakistani rupees caused huge capacity payments.
108
Power Sector
▪ Higher outages and higher capital costs were allowed making capacity purchase
prices higher (Sohail, 2014).
▪ For IPPs, the up-front tariff regime under Up-front Tariff (Approval & Procedure)
Regulations, 2011, is generally applied. But regulator incapacity to determine
upfront tariff often results in higher tariff calculation35. This is one of the
reasons, for the in�lated cost of electricity generation in Pakistan (Malik, 2022c).
Figure 10.3. Anomalies in Tariff Calculation
▪ Actual heat rate/ef�iciency of GENCOs plant is more than NEPRA determined heat rate;
additional heat rate consumed per unit produced is not covered in any tariff.
▪ Increased pay and allowances due to hiring employees in GENCOs, NTDC and DISCOS
beyond NEPRA-determined staf�ing cost, and is not covered in any tariff (generation,
transmission and DISCOs).
▪ NTDC tariff is set on 2.5% transmission losses, whereas actual losses are much higher.
As a result, the cost of excess transmission loss is not recovered from any tariff, which
ultimately adds to the circular debt.
▪ Late payment surcharges paid by CPPA-G to the IPPs resulting from the inability of the
DISCOs to pay for the power cost on time are also not covered in any tariff-setting
mechanisms.
▪ Network loss is more than NEPRA-determined T&D loss for most DISCOs. It ranges from
0.04% to 17% among ef�icient performing DISCO to worst performing DISCO. The cost
of excess loss above the NEPRA-determined loss level is not recovered from any tariff; it
is added to CD.
▪ Poor revenue collection by the DISCOs due to which liabilities of the power sector towards
power cost is not being paid. This poor revenue collection adds to the CD and leads to
load shedding.
▪ Prolonged stays on fuel price adjustments granted by the courts and impact of court
decisions that delayed payments to DISCOs.
10.3. CONSUMER-END TARIFF
▪ NEPRA determine consumer-end tariffs for each DISCOs separately. NEPRA

determines consumer-end tariffs to recover the entire supply chain costs.
35For instance, imported coal power plants (under CPEC) had been built at $1.4 million per MW and a tariff
almost double to a similar coal plant tariff under construction in UAE by the same Chinese company at the
same time. The reason was the upfront tariff system of NEPRA. NEPRA estimated a high tariff.
109
Power Sector
▪ In deciding the average sale price, NEPRA considers the annual revenue
requirement of DISCOs which includes all the costs involved. The main factors
in the annual revenue requirements include power purchase price36, net
distribution margin37, T&D losses, and prior-year adjustments38, as illustrated
in Figure 10.4
Figure 10.4. Consumer-end Tariff (Rs/KWh) FY2020
25.00
20.00
15.00
10.00
5.00
0.00
IESCO LESCO FESCO GEPCO MEPCO SEPCO PESCO TESCO HESCO QESCO
-5.00
EPP CPP UoSC PYA Dist. Margin T & D Losses Av.Tariff
Source: SROs 182(1)/ 2020 to 190(1)/2020 (February 12, 2021)
▪ NEPRA is not autonomous in its decisions on consumer-end tariffs. The GOP

continues to exercise considerable control over it. Thus, affecting NEPRA’s
effectiveness in determining/ regulating consumer-end tariffs as per the actual
cost of service (under Section 31 (3h) of the NEPRA Act).
36 It includes the generation and transmission costs of the power a DISCO has projected to purchase.
37 It is the difference between gross margin and other income of DISCO. Gross margin includes O&M costs,
depreciation and returns on the asset base of DISCO. Other income refers to remuneration of deferred credit,
meter and rental income, late payment surcharge, profit on bank deposit, sale of scrap, income from non-
utility operations, commission on PTV fees and miscellaneous incomes.
38 It is the gap between the projected and the actual cost in the previous year, built into tariffs for that year.
This adjustment is for the difference between the projected and actual electricity units purchased by DISCOs;
the difference between the projected and actual distribution margins; the difference between actual and
notified previous year adjustment; the difference between projected and actual other income; and the
difference between the projected and actual consumption mix.
110
Power Sector
▪ Although no formal condition or rule allows the Ministry to reverse NEPRA’s

decisions, major decisions, i.e., tariff rates, are subject to Ministry approval.
The regulator determines tariffs and can only recommend what the Ministry
notify39.
▪ The tariff which the GOP notifies reflects the political and socio-economic
objectives.
Uniform Tariff
▪ Under the NEPRA Act 1997, the tariff so determined was different for each
DISCO because of its distinct characteristics: the difference in annual revenue
requirement and T & D losses.
▪ NEPRA used to make its valuation of cost and revenue requirements, determine
the average sale price of each DISCO, set tariffs for different slabs of various
categories of consumers for each DISCO, and send its recommendation to the
GOP (PD).
▪ The GOP notified the final tariff for different consumer categories but the same
across all DISCOs. The GOP notifies the uniform tariff after adjusting for subsidies.
Before the amendment to NEPRA Act, the minimum consumer-end tariff for a
particular consumer category among all DISCOs was adopted for application
across the board to all DISCOs.
▪ After the amendment to NEPRA Act, NEPRA is determining a uniform tariff for
distribution licensees wholly owned and controlled by a common shareholder
based on their consolidated accounts. It compromised the inefficient behavior
of some of the DISCOs. The GOP notified the final applicable tariff after adjusting
for subsidies.
▪ The repeated build-up of equalization surcharges to ensure uniform rates has

compelled honest consumers to switch to alternate sources. Potential industrial
consumers have set up their captive plants, and residential consumers are
shifting to individual solar systems / micro-grids. This is sparing existing power
capacities and increasing capacity payments.
39 The Act binds the Authority to do so.
111
Power Sector
Electricity Tariffs as Mean of Collecting Taxes/ Surcharges
▪ Several surcharges levied by the GOP are also included in the consumer-end
tariff by NEPRA under Section 31(1) of the NEPRA Act 1997. This section deals
with the acceptance of the various directives/advisories of the GOP, provided
these do not clash with the basic principles of the ActFor instance, financial cost
surcharge of Rs 0.43 per unit (for debt surfacing of circular debt parked in PHPL),
▪ Neelum Jhelum Surcharge of Rs 0.10 per unit,
▪ Sales tax @ 17%, TV fees of Rs 35 per meter and electricity duty @1.5%;
sales tax is also charged on fuel price adjustments.
▪ These are charged irrespective of units consumed.
▪ It increased costs to compliant consumers; surcharges can also result in more

inefficiency in the distribution system. It reduces DISCO's incentives to improve
and control costs.
▪ In the case of the Neelum-Jhelum project, the surcharge shifts utility business
risks away from investors and puts extra pressure on consumers.
▪ The consumer-end tariff has become a means to collect taxes, i.e., as an agent
of the FBR. It is unique, as the most developed world does not cater to such
collection(s).
▪ The proliferation of these surcharges generally shifts risks away from utility
operators/ investors and onto consumers.
112
Power Sector
Figure 10.5. Electricity Bill Dissection
GST on Fuel Price Adjustment

Income Tax 2%
GST 6%
12%
Electricity Duty
1%
Quarterly Tariff
Surcharge
6%
Financial Cost
Surcharge
1%
Cost
62%
Fuel Price
Adjustment
10%
*Random Residential Electricity Bill for June 2022; Income tax is not charged from tax �iler
Tariff Accommodating Inef�iciencies
▪ The tariff break-up suggests that the customer is billed for all possible expe-
nditure(s) in the power sector, including inef�iciencies, e.g., high transmission
& distribution losses and low recoveries, wrong billing, mismanagement, etc.
The power sector is plagued with inef�iciencies that see no reduction; so is the
upward trend in consumer-end tariffs.
▪ Apart from monthly fuel price adjustments, NEPRA also allows for quarterly
adjustments in the determined tariff of DISCOs. It is made when DISCOs do not
use the allowed energy quota and ask for a quarterly adjustment. Instead of
regulating DISCOs (regulatory failure), the burden is transferred to the
consumers. The tariff increase on this account is responsible for a hike of about
50% during the last two years.
113
Power Sector
Cross-subsidy within and across Sectors
▪ For the end-consumer, the current tariff structure is uniform throughout the
country; it distinguishes between residential, commercial, industrial, agriculture,
and other customer categories, further divided by consumption level (tariff
slabs), load, or time of use.
▪ The system of electricity subsidies and cross-subsidization across sectors and
different geographical regions_ DISCOs, and the inability to pass on the actual
cost to some consumer categories is of great concern.
▪ A tariff structure in which charges are not recovered from all consumer categories
indiscriminately, besides creating �inancial dif�iculties for the government, also
creates inef�iciencies and misleads investment decisions in the supply system.
Box 10.3. Power Sector Subsidies
▪ The Government of Pakistan provides several subsidies to the power sector. The most
signi�icant portion of this subsidy is for inter-DISCO tariff differential. Out of Rs 366.4
billion of electricity subsidy in FY2021, 55 per cent (Rs 201.8 billion) was for inter-
DISCO tariff differential, and about 2 per cent (Rs 7.5 billion) was for Agriculture tube
wells.
▪ Since FY2007, the government has paid over Rs. 3.4 trillion subsidies to the sector, out of
which about 75 per cent are for the uniform tariff policy.
▪ Due to �iscal constraints, the government cannot manage this subsidy amount in time,
consequently adding to the sector’s de�icit (that is, circular debt).
▪ The consumer tariff noti�ied in February 2021 created a �inancial gap of more than Rs
180 billion, to be covered through direct subsidies by the government. This is apart from
tariff hikes due to fuel and other adjustments.
▪ These subsidies and price structures discourages inef�icient companies from improving
their performance. If a different tariff is charged in each DISCO_ it will create pressure on
companies like SEPCO, HESCO, PESCO and QESCO to improve, but companies like IESCO,
The provision of different tariffs for each distribution company based on its peculiar
circumstances was conceived in the NEPRA Act 1997. Initially, the burden to make the
differential tariff uniform for all consumers in Pakistan was on the Federal Government.
114
Power Sector
However, afterwards, the GOP introduced the mechanism of cross-subsidization across

DISCOs. This approach is against the spirit of the reforms plan introduced in the early
1990s and the Companies Act. Additionally, it is against the ef�iciency requirement in the
power sector.
Figure 10.6. Residential Tariff Slabs (Rs/ Figure 10.7. Agriculture Tariff (Rs/
KWh) KWh)
Average Uniform Tariff Determined Average Uniform Tariff Determined
GOP Applicable Tariff Applicable Tariff
22.7 22.9 23.8
25 19.6 21.4
25
20 12.2 17.6
15 10.1 20 14.3
7.7 19.1 20.6 13.0
10 4.0 16.4 17.5 15 20.6
14.6 17.6
5 10
0 13.3
4.0 5
7.3 7.3 7.3
its
its
its
its
its
its
0
un
un
un
un
un
un
00
e
50
ov
20
30
70
-1
ak
ak
k
l
to
el
ab
1-
1-
1-
ea
ea
51
ar
Up
Pe
pe
w
10
20
30
Sc
fp
-P
d
be
U-
an
ff
TW
Of
Tu
-O
TO
0
U-
TW
70
TO
Figure 10.8. Industrial Tariff (Rs/KWh)
Average Uniform Tariff Determined Figure 10.9. Commercial Tariff (Rs/

Applicable Tariff KWh)
25 20.8 20.7 20.7 20.7 Average Uniform Tariff Determined

18.3 Applicable Tariff
20 17.2 15.2
16.7
15.0 14.9 14.8 23.6
21.2 21.0 21.1 20.9 20.0 21.6 20.3
15 18.3 25 17.6
17.9 18.4
20
10 13.4 13.5 15 21.0
12.6 13.0 19.6 19.2 19.2
10
5 5 13.5
0
0
a…
…
r
ak
k
la
ea
ry
Pe
B1
B2
ak
ak
B3 e a k
B4 e a k
Of ak
O ak
ly
gu
th
fp
ra
ea
ea
pp
U-
Pe
Pe
B3 Pe
B4 Pe
Re
ss
po
of
f-P
f-P
f-P
po f f - P
TO
su
le
U-
B1
B2
m
Of
Of
ad
ry
TO
Te
B1
B2
ra
Lo
m
te
Source: SROs 182(1)/ 2020 to 190(1)/2020 (February 12, 2021)
115
Power Sector
10.4. LOAD SUPPRESSION TARIFF (INCREASING BLOCK TARIFF) MODEL
▪ About half of the total electricity consumed is in the domestic sector. The tariff
structure is progressive for domestic consumers. It is expensive at higher
consumption levels (Figure 10.6).
▪ Since 2013-14, the tariff structure has moved from all slab bene�its to only a
previous slab bene�it. The residential consumers are given the advantage of
one last slab40.
▪ For residential consumers, the price of electricity is greater than the supply
cost in the higher slabs
▪ The load suppression model for the consumer-end tariff was designed to
constrain usage and ensure that the high-paying domestic and commercial
consumers subsidize the low-end users or the marginalized consumers of
electricity.
Figure 10.10. Electricity Consumed by Sectors (% share) FY1995
Bulk Supply & Others

Public Lighting 10%
1%
Domestic
Agriculture 38%
15%
Industry Commercial
31% 5%
Source: NEPRA State of Industry Report (2021) and NTDC Electricity Marketing Data (2022)
40 In September 2022, the one-slab bene�it is also removed.
116
Power Sector
Figure 10.11. Electricity Consumed by Sectors (% share) FY2021
Bulk Supply & Others

12%
Public Lighting
0%
Agriculture
8% Domestic
48%
Industry
25%
Commercial
7%
▪ Even though NEPRA now regulates the power sector, the earlier tariff structure,
inherited from WAPDA, has been retained.
▪ The inherited load suppression model went well until the sector operated in
de�icit mode. However, it is unsuited for the energy surplus regime (Figure 10.12).
Figure 10.12. Peak Demand and Supply (MW)
50,000
45,000
40,000
35,000
30,000
25,000
20,000
15,000
10,000
5,000
0
86
88
90
92
94
96
98
00
02
04
06
08
10
12
14
16
18
20
22
24
26
28
30
19
19
19
19
19
19
19
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Supply Peak Demand
117
Power Sector
▪ WAPDA designed the load separation model of tariff to provide for the socio-
economic obligations of the state. Pakistan’s earlier thought process was
towards being a welfare state41. In those days, the concept of cross-subsidies
was considered kosher. The recurring energy crises further compounded the
situation (Box 10.4).
Box 10.4. History of Energy Crisis in Pakistan
▪ First, an energy crisis erupted before the commissioning of Mangla Dam in 1968.
▪ Second, it started in the early 1970s and continued till the commissioning of Tarbela Dam
(four units of 700 MW) in 1977. Both Mangla and Tarbela dams led to a robust hydro-based
energy generation that satis�ied rising demand, but only for a few years.
From 1960 to 1973_ DBT, i.e., high rates for initial units and lower on succeeding units. In
the 1960s, 60 % of the electricity was produced from hydro sources; therefore, initial units
were expensive to cover the capacity price.
▪ Third, energy demand soared, which the existing generating capacity could not match.
Thus, leading to energy crises in 1984 and onwards. The crunch saw the unveiling of the
1994 power policy and the induction of IPPs
▪ Fourth, it started in 2005 and ended in 2017 (in terms of suf�icient installed capacity).
These crises ensured that the demand had to be suppressed. Thus, the tariff structure
based on the concept that the more you use, the more you pay was applied, against the
worldwide principle of reduced rates for bulk sales. This tariff model continued against
its basic principle between 2000-2004 when power was in surplus. Even after 2018’s
power glut, the model continued.
Over the last twenty-�ive years, the fast urbanization trend along with the subsidized
electricity tariffs have increased the share of domestic consumers while denting industrial
usage (Figure 10.10 and Figure 10.11). Some de-industrialization is obvious. But primarily,
high electricity tariffs for industry have led to the advent of Captive Power Plants. These
have become a competitor to the institutionalized power sector of Pakistan. Besides, the
availability of alternative energy sources has led to the reduction in industry usage of grid
electricity in the presence of high tariffs and shortage of grid electricity in the latest
energy crisis phase.
41 In line with the earlier socialist leaning period.
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Power Sector
Glitches in Current Tariff Structure
▪ Load suppression (increasing block) tariff formulation goes against the

fundamental spirit of a regulated sector whereby the cost of service for each
category of consumers makes up the tariff.
▪ There are six tariff slabs for household category, which in itself is exemplary
and leads to the inef�icient use of electricity.
● For those who consume up to 300 units of electricity, the applicable uniform
tariff is much lower than the NEPRA determined uniform tariff.
● Most of the time, any increase in tariff is only applicable to those who
consume 300 plus units.
● As per the tariff noti�ication of February 12, 2021, 67 per cent of domestic
consumers use electricity up to 300 units, while the remaining 33 per cent
consume electricity above 300 units in Pakistan. In other words, 67 per
cent of the consumption is below the weighted average cost of service.
● This government policy is meant to insulate the poor and the lower middle
income (0-300 units) from the tariff hike.
● It is dif�icult to determine whether those consuming up to 300 units are
deserving or not42.
▪ Uniform tariff policy is counter-productive, as it leaves no attraction for ef�icient

DISCOs to further improve or remain ef�icient and offers no incentive for the
poor and loss-making DISCOs to reduce losses and become ef�icient.
● As per National Electricity Policy 2021, the uniform tariff policy will
continue_ meaning the continuation of tariff differential subsidy. A
uniform tariff policy is no incentive for a privatized or a state-owned
corporate entity.
● The ultimate objective of CTBCM is to generate competition among
market players to bene�it consumers in terms of service quality and
pricing. There will be no competition when accounts of inef�icient and
ef�icient DISCOs are treated as one, and the uniform tariff is charged.
42 About 46 per cent of the population is not connected to the national grid in rural areas. In urban areas,
poor and lower-middle-income households that presumably consume (0-300 units) reside typically in
congested localities. However, there are apprehensions that crowded areas mean more power theft
(through meter-tempering) and line losses. .
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Power Sector
▪ No realization at the government level that an increase in tariffs expands the

black hole in the power system_ halting efforts to reduce aggregate transmission
and commercial losses present. Any tariff increases lead to a higher �inancial
gap.
● In 2021, T & D losses were equivalent to Rs 473 billion, Rs 402 billion

were recovered through tariff, and a �inancial loss of Rs 71 billion was
added to CD. Power sector loss from low bill recovery was Rs 39 billion
in the same year. Unless or until tariffs are not allowed to cover the actual
cost of service to consumers, the power sector will continue to face
�inancial dif�iculties, and the CD will continue to rise.
Pakistan is among the top thirty countries globally with relatively high tariff rates. A
complete revamping of the present consumer end tariff is needed. Linear Tariff, as
illustrated in Box 10.5, is an option adopted in several countries.
▪ As Clause 31 of the NEPRA Act speci�ied, cross-tariff subsidies should have been
shunned, as rightly contained in the original NEPRA Act, but it did not happen.
Subsidies are a part of the state's socioeconomic or political obligations, which
must not burden the high-end domestic consumers, commercial consumers,
and industrial categories. It is against the independence of NEPRA.
▪ Better performing DISCOs and compliant consumers cross-subsidize inef�icient
DISCOs and consumers involved in illegal electricity use.
● DISCOs in Punjab only allowed technical losses in tariff calculation. Still,

their consumers are burdened with the extra cost of electricity due to bad
governance in DISCOs in other geographical areas.
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Power Sector
Box 10.5. Linear (Flat) Tariff and Different across DISCOs
Based on data from Tariff Determination of February 12, 2021, total revenue is estimated for
NEPRA determined uniform tariff, GOP applicable tariff, and for a �lat (linear) tariff, i.e., the
weighted average across DISCOs. Maximum revenue is generated if we apply a linear (�lat)
rate which (in this case) is the weighted average across DISCOs, without any subsidy. However,
the �lat (linear) tariffs may not be a win-win situation for all (e.g., poor households) but will
reduce tariff-related distortions and inef�iciencies. Empirical literature highlights that direct
cash transfers, compared to electricity subsidies, have proved to be a better welfare alternative
for low-end consumers.
Revenue Generated using Different Tariffs
Sector Sales across Total Revenue Generated (Rs Billion)

DISCOs
NEPRA Determined Govt. Applicable Flat (Linear) Tariff (Weighted
GWh Uniform Tariff Tariff Average across DISCOs)
Residential 48948 828.61 650.57 816.94
Industry 25857 371.42 411.11 431.55
Commercial 7117 121.66 137.97 118.78
Agriculture 10405 166.01 79.15 173.66
Single Point 3327 49.53 69.13 55.53
Gen. Services 2575 43.9 50.24 42.98
Public Lighting 287 5.46 5.92 4.79
Res. Col. 59 1.24 1.22 0.98
Total 1,587.83 1,405.31 1,645.22
Revenue Generated using uniform and different Flat (Linear) Tariffs Across DISCOs
(Rs Billion)
IES LE FES GE ME S PE T HE QE Tota

CO SC CO PC PC E SC E SC SC l
O O O P O S O O
C C
O O
Flat (Linear) Tariff 161.1 369.6 229.19 168.65 277.9 58.43 187.50 28.56 73.14 91.04 1,645.22
(Weighted Average 1 8 2
across DISCOs)
Flat (linear) rate different 137.9 354.1 223.28 158.55 281.0 75.48 189.97 24.88 100.65 102.77 1,648.79
across DISCOs 4 8 9
Source: Malik and Urooj (2022)
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Power Sector
Action Points
▪ Notify differential tariffs for each geographical market (DISCO), that is, tariff
determination based on service cost.
▪ Recover the total service cost from all consumers; no cross-subsidization across sectors
or regions or high-end consumers.
▪ NEPRA must be empowered to play its role as speci�ied in Clause 31 of the NEPRA Act.
NEPRA should eliminate all kinds of subsidies and cross-subsidies from the tariff.
▪ NEPRA needs to simplify processes to minimize delays.
▪ NEPRA needs to build its capacity to work and cope with sector challenges and market
forces while meeting its obligations as a regulator.
The tariff (and its components) calculation expects technical and administrative analysis
with innovative technical and commercial performance tools. The power sector can only
improve if the actual cost of a power supply reaches every consumer
▪ NEPRA must consider technical analysis or use speci�ic parameters to identify

challenging areas (with poor law and order situations) for controlling theft and bill
recovery.
▪ For recovery of capacity payments, there is a need to increase sales/ consumption
by reducing prices signi�icantly and making grid electricity attractive to productive
sectors (service provision is cheaper for the industry than domestic consumers) by
offering them lower tariffs.
▪ Transitioning from a de�icit regime to a surplus one requires changing the load separation
model of power tariffs to a linear tariff regime for increasing ef�iciency and revenues.
▪ We have a social protection system. There is no need to subsidize electricity. All the socio-
economic and political obligations of the government must be duly budgeted.
▪ Simpli�ication of consumer-end tariff where a consumer pays only for the cost of electricity
and does not become an agent of FBR.
There is a stark difference in electricity usage between day and night. Likewise, seasonal
variation in electricity usage is high in Pakistan. Summers and winters differ in demands
of anything between 8,000 to 13,000MW.
▪ Regulator must reconsider the present TOU tariffs by catering for at least four different
segments of the day and then for the four seasons – speci�ically, the high summers and
the winters.
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Power Sector
11. COMPETITIVE TRADING BILATERAL CONTRACT

MARKET (CTBCM)
The electricity market is complex; it requires careful planning and a design developed
keeping in view the ground realities. In Pakistan, the power sector has certain peculiarities.
Establishing a donor-designed power exchange market in the current scenario seems
impracticable.
11.1. PREFACE
In November 2020, NEPRA approved a detailed design and implementation roadmap for
the CTBCM prepared by CPPA-G through an international consultant (MRC Consultants
and Transactions Advisor) with the support of the Asian Development Bank. NEPRA gave
18 months to CPPA-G for its preparation and implementation.
▪ Under this model, existing PPAs between IPPs and NTDC/CPPA-G (on DISCOs'
behalf) will be converted into bilateral contracts between each IPP and DISCOs.
▪ The model envisages that all future contracts for the sale/purchase of electricity
will be bilateral between the parties: sellers - generation companies and buyers
- distribution companies or bulk power consumers
11.2. CTBCM PRIMARY COMMERCIAL FEATURES
▪ Demand participants (DISCO, KE, Suppliers, and BPCs) will sign contracts
directly with generators (traders) to cover their energy needs and capacity
obligations.
▪ At the start of the wholesale electricity market, there will be two types of
contracts: pre-existing PPAs and new contracts signed under the new market
framework: the Supply Contracts.
▪ New capacity procurement for DISCOs will be done through centralized competitive
tenders or an auction.
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Power Sector
▪ An Agent will aggregate the capacity and energy required by each DISCOs and
run the procurement for the total requirement.
▪ For the bilateral contracts, the settlement, invoicing, and payment will be made
directly between the PPA partners, e.g., the generator and traders on one side
and DISCOs, suppliers and BPC and any other buyers on the other side.
▪ There will be a balancing mechanism to settle deviations between contracted

and actual amounts. Settlement of contract deviations in the balancing
mechanisms will be done by the MO.
▪ The market will include mechanisms to address non-payment risk. The bilat-
eralization of existing contracts will not change the guarantee that is part of
the existing PPA.
▪ For DISCOs that cannot provide the required guarantees (for bilateral PPAs)
or credit cover for participating in the balancing mechanism (e.g., DISCOs with
a history of low collections and low payment records), the Government could
provide a guarantee or credit cover.
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Power Sector
Figure 11.1. CTBCM
Source: CPPA-G (www.cppa.org.pk)
11.3. CURRENT MARKET STRUCTURE: SINGLE BUYER MODEL

The power system operates as a single-buyer model where the CPPA-G buys power from
GENCOs, IPPs, WAPDA and other producers, pools it, and sells it to all the DISCOs.
▪ The single-buyer model, instead of motivating ef�iciency, transmits inef�iciency

to consumers through increasing tariffs.
▪ The single-buyer model is considered the second-best alternative to compre-

hensive restructuring, providing time for a smooth transition toward fully
competitive wholesale markets. Nevertheless, it is a risky transition; rigid
contracts with IPPs can deter participation in a subsequent competitive market.
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Power Sector
▪ The in�lexible long-term PPAs, built around take-or-pay clauses, deter the
evolution of competition. The plants operating under the agreements will have
no incentive to participate in a competitive market. To minimize short-run
production costs, they cannot be dispatched on a merit-order basis, as is
currently happening in Pakistan.
11.4. WHOLESALE MARKET FUNDAMENTALS
Effective Stable
Financially Macroeconomic,
Regulatory Political &
Viable Sector
Infrastructure Social Environment
Adequate Independent System

Political Transmission and Network
Commitment Network Operator
Non-discriminatory Several Buyers Complete

Legal Frameworks and Sellers Unbundling
The electricity market is complex. It requires careful planning and implementation because
of its complexities, technicalities and inelastic demand and supply. Otherwise, a market
can collapse even with abundant resources, e.g., California’s Power Market in 2000 (Box
11.1).
Following is a brief depiction of all the peculiarities of Pakistan’s power sector that impede
the establishment of a fully operational power exchange. Due to these, the quick induction
of CTBCM modules is suspect.
▪ A reliable payment chain is crucial for a market to function. The creditworth-

ness of all, particularly distribution utilities, is critical. Presently, the power
sector is not fully solvent and is in de�icit.
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Power Sector
● The payment culture is not disciplined, and there is an inability at part

of the demand to pay in advance.
● In the CTBCM, because of take-or-pay long-term PPAs, the distribution
companies would be required to provide credit cover for future power
procurement. It is not possible, given the current poor balance sheets
and structural weaknesses of the DISCOs. If buyers, that is, DISCOs, are
�inancially unsound, the envisaged wholesale and retail power market
will not be able to function.
The only chance (almost negligible) is that CTBCM would stay in Punjab, where DISCOs
have relatively better balance sheets. For others, if the government is going to provide
credit cover/guarantees, what is the point in having such a market?
▪ Due to in�lexible long-term PPAs, it is not easy to free volume from signed PPAs
for power exchange. All demand is already contracted by take-or-pay capacity,
i.e., the buyer pays the total �ixed costs, including their returns, procuring energy
at their regulated variable cost. Therefore, participation of the demand is not
foreseen in voluntary exchange and increases the cost of purchasing by paying
the market-clearing price in power exchange.
▪ The bene�its of competition are unlikely to pass to end-users if market power
is concentrated in the generation or distribution sector.
▪ Though the state-owned CPPA-G is an independent MO, it has a clear bias favoring
DISCOs; a non-discriminatory governance structure is impossible.
▪ Demand forecasts are not mature enough for ex-ante imbalances settlement.
▪ The electricity act in Pakistan does not allow the self-dispatch of plants.
▪ Transmission constraints, which will restrict the self-dispatch at various nodes.

Readjustments will be dif�icult; in most cases, the contracts will not be dispatched.
▪ As per the NEPRA amended Act 2018, distribution will be separate from the
electricity supply by 2023, which requires new standards/rules/regulations.
Regulatory requisites are not in place.
▪ DISCOs do not have the capacity and understanding of the market.
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Power Sector
Box 11.1. California Electricity Market Crisis (2000)
Reasons:
▪ Shortage of Generation Capacity_ market manipulation by generators, increase in input
costs, regulatory uncertainty, and slow environment review process.
▪ Bottlenecks in Related Markets_ constraints on related infrastructure and markets, including
natural gas pipelines, the market for pollution permits, and the electricity transmission system.
▪ Wholesale Generator Market Power_ allegations of market manipulation.
▪ Regulatory Mistakes_ retail prices were capped, but utilities were forced to buy expensive
wholesale power instead of short-term price controls on wholesale markets. Excessive
reliance on the spot market and the division of regulatory authority increased the
opportunities and incentives for strategic manipulation of the markets.
▪ Faulty Market Design_ overall, the design was complex, relying much more on market forces.
The electricity market works entirely on the supply side while ignoring demand-side
management.
Outcome:
Increase in wholesale electricity price. Retail prices were frozen. Utilities lost millions of US$
per day, and their debt increased rapidly, as much as US$ 50 million per day.
Sources: Borenstein (2002) and Weare (2003)
11.5. DISTRIBUTED GENERATION (DG) AND WHEELING OF POWER

DG is a norm in electricity markets globally. DISCOs are creating hurdles in allowing "
wheeling" and "net-metering" regimes, which are supposed to bring competition to the
sector. As in the draft National Electricity Plan, 'wheeling' would only be allowed as any
viable proposition after billing all so-called stranded costs, etc.
Instead of approving the B2B sale of power arrangements, a new scheme, CTBCM, is being
hyped as the new panacea of all ills. CTBCM might create due ripples in the power market,
but the main issue that will still need to be solved would be power wheeling. As the PD is
presently managing the sector (DISCOs), it considers 'wheeling' a distinct threat to its
viability. Thus, it would keep dragging its feet and put all possible obstacles in the path.
The case of net-metering is no different43 .
43 An amendment in NEPRA Distribution Generation and Net-metering Regulation, 2015, is planned to

favor DISCOs. After this amendment, the currently applicable national average power purchase price of
Rs. 19.32/kWh will be replaced with the national average energy purchase price of Rs 9/kWh. This move
will disincentivize net-metering consumers.
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Power Sector
The 'wheeling of power' for the BPCs must force its way (against all obstacles – including
that created by the PD) in 2-3 years. That would be the precursor for the power market.
Because of this facility, the small BPC population of the country would have their energy
costs reduced, along with the availability of standard supplies. 'Wheeling of power' allows
open access to all market participants on a non-discriminatory basis and attracts new
investments.
Key Takeaways
Establishing a power exchange market in Pakistan in the current scenario seems impracticable.
Nevertheless, the Federal Government, CPPA-G and NEPRA are implementing the CTBCM44.
The statement by Chairman NEPRA that he envisages only baby steps to implement
CTBCM is a pointer towards the sectoral confusion moment45. Moreover, the timeframe
given for its implementation is over, yet the implementation of CTBCM is not in sight.
As in the amended NEPRA Act, if the accounts of poorly managed and ef�icient DISCOs
are treated as one, the tariff will continue to be uniform across the country (National
Electricity Policy, 2021). There is no point in spending time and energy on CTBCM. The
proposal is counterproductive as it leaves no attraction for ef�icient DISCOs to improve
further or remain ef�icient and offers no incentive for the loss-making DISCOs to reduce
losses and become ef�icient.
The energy sector will lose its monopolistic status (in favor of consumers) only if the
amended NEPRA Act is implemented in letter and spirit. That is the complete separation
of 'wire' and 'retail' business. Small new retailers would enter the system using DISCO'
wire' to distribute electricity, creating competition. DG and net-metering offer retail
competition provided it is allowed unhindered.
44 Competitive wholesale market with a balancing mechanism was supposed to start in April 2022. Now,
the process is underway under a USAID project.
45 Chairman NEPRA's statement, carried by the Express Tribune of 19/10/2021.
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Power Sector
Recommended Path
▪ The market should start with bilateral contracts keeping transmission constraints
and participants' capacities in mind. When demand and supply balance and the
market attain more maturity, establish an electricity trading platform.
▪ All DISCOs should be allowed to purchase energy on a short-term contract and

acquire generation assets falling inside their territorial jurisdiction and outside.
▪ Start with the 'wheeling of power' – electricity transmission from a producer to

a user in the same balancing area or from one location to another. NEPRA should
facilitate 'wheeling' by discouraging the hurdle creating entities.
▪ Wheeling needs to be supported by drafting priority requisite policies and plans

at the governmental level.
▪ On the generation side, negotiate PPAs with IPPs to free at least 50 per cent of
their capacity to be traded in the market.
▪ The electricity market requires legal, regulatory, �inancial, and human capacity
at every level - build this capacity �irst.
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Power Sector
12. FUTURE ARCHITECTURE OF THE POWER SECTOR
The sector is mired in 1960s technology in content and design. It lacks coordinated
planning and policymaking. There is mismanagement, weak governance, and an
ineffective regulatory regime. Immediate corrective measures are required to move
from stagnation to a developed system in the 21st century. A regional grid is seen
around the corner, linking Pakistan with the Central Asian Region, Afghanistan,
and Iran. There is a strong possibility that the rest of the Indian sub-continent may
also become a part of this grid. Before we look into the future, we must come out
of the stale system.
12.1. MANAGERIAL REFORMS

Human Resources Management (HRM) and Human Resource Development (HRD) are
compulsory for a successful entity. Currently, because of recruitment issues (intermittent
instead of regular), both HRM and HRD are hit. There is a perpetual scarcity of staff. The
planning cannot be undertaken when the public sector companies are neither government
entities nor governed by the Corporate Companies Act.
There is a disconnect between the Public Sector Corporatized Entities (PSCES) and WAPDA
(the original provider of HRD modules). Thus, the development of the PSCE’s staff is
compromised. This aspect needs special attention to be resolved.
▪ To resolve this issue between WAPDA and the PSCEs: upgrade, rather quickly,
the Training Institute(s) of WAPDA, considering the present-day requirements.
▪ Secretary, Power Division, and MDs of all relevant organizations should be
competent power engineer(s).
▪ Professional BODs should be authorized to hire CEOs having experience in
distribution and expertise in managerial affairs.
▪ CEOs should be given all administrative, technical, and �inancial powers to
run the DISCOs without government interference.
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Power Sector
▪ The BODs should necessarily and pre-dominantly comprise sectoral professionals

and non-political people, while the number of GOP nominees should be minimum.
▪ GOP nominees should not dominate the BODs' decision-making.
More details on senior management challenges are in Appendix C.
12.2. RE-ORGANIZE POWER INSTITUTIONS & REDUCE GOVERNMENT

FOOTPRINT
Regarding governmental support for power sector operations, only a little change is
expected as the governments in Pakistan will remain mired in usual governance issues
without leaving any time for the utilities. The generalist is expected to stay at the Ministry
of Energy beyond 2030.
▪ The �irst module that needs change is reducing the government footprint and
ultimately moving the government out of the power sector (latest) by 2030.
▪ The second is effective regulatory infrastructure.
132
Power Sector
Figure 12.1. Power Sector Institutional Pro�ile
Government Of Pakistan
Market Operator Executive Oversight
Board Of Ministry Of Energy Pakistan Atomic Provincial

Cheif Executive
Departments NEPRA
Investment (Power Division) Energy Commision Of�icer
PPDLC
Administrative Oversight
CPPA CHASHNUPP Punjab
PPDB
Mega Dams
WAPDA KANNUP EPDS
Sindh
Project
TCEB
GENCOs
KPK
Initiate, coordinate & PEDO
monitor energy NEECA GB-PDB
conservation actions GB
WPD GB
Promote Renewables AEDB IPPs
AJK
AJK HEB
PPIB
AJK PPC
Fascilitate private NESPAK
investors
NPPMCL
PECO/PPMC Monitor Power Project Development
DISCO NTDC
DISCOs PEPCO/PPMC
K-EI
PTIC provide IT support PITC SPPs/CPP

to PEPCOmanagement &
DISCOs Regulatory Oversight (Monitoring) by NEPRA
Source: (Malik, 2022b)
Currently, more than 20 institutions, excluding distribution and generation companies,

are directly involved in the power sector. There are several institutions with overlapping
functions (Figure 12.1). The existence of several institutions is questionable.
▪ What's the point in having PPIB and AEDB in the presence of the BOI and NEPRA?
▪ At least three organizations, NEPRA, CPPA-G and PEPCO, now PP&MC, are
responsible for monitoring and regulating the management and operations
of distribution companies.
133
Power Sector
By law, DISCOs are independent corporate entities with independent boards. Its operations
and reforms (if required) are the responsibility of company management and the board.
No other institution (PP&MC or CPPA-G) needs to manage, monitor, or regulate its �inancial,
commercial, and operational affairs. Let DISCOs grow independently_ �inancially, and
administratively outside the umbrella of PEPCO or PP&MC. In other words, from donor
in�luence_ all government departments are running under the technical assistance of
donors like WB, ADB and USAID.
Likewise, in future, CPPA-G will act as a MO and SO, but only when the wholesale market
is functional. NPCC (NTDC) has been performing duties as a SO, and in the past of MO,
why CPPA-G? So many parallel sector entities (including NEPRA) cannot safeguard people's
interests.
▪ Shutting down a few and merging the remaining twenty-plus free-�loat entities
operating now into a single National Energy Authority could bring about sanity
and coordination in the energy sector.
A uni�ied (NEPRA + OGRA) energy regulator is on the cards (as in the draft Energy Plan).
The need for more experts to staff the uni�ied regulatory authority would remain an issue.
It will take another �ive years for the new entity to graduate.
On paper, the regulators are designed to be independent, to monitor and regulate the
energy sector, but presently, their ef�iciency depends upon the ministry concerned. If it
continues, then the future of independent regulation is bleak.
▪ The job of the GOP is to monitor the effectiveness of a regulator, not interfere.
Yet, the authority must be held accountable if not performing effectively.
▪ About the regulatory regime, it is critical to suggest that the future would like
to see the creation of provincial regulator(s) as the distribution of power would
ultimately have to become a purely provincial subject with a national grid.
The most complex and therefore requiring strong political will is restructuring policy
institutions to reverse the unchecked fragmentation that has occurred over the years in the
power sector. Cutting down these institutions and consolidating the remaining can streamline
the energy sector more effectively.
134
Power Sector
12.3. ALL-INCLUSIVE POWER POLICY & COORDINATED PLANNING

Pakistan's Power sector needs an all-inclusive national power policy, which allows the
country to move forward in quest of the laid down goals of �inancial viability with no sector
losses and no �inancial burden for the government. On the contrary, for consumers, which
allows for reliable supplies at affordable prices.
We need a power policy considering federation challenges, a national goal and subsequent
planning and implementation strategies.
Without goal-speci�ic policy direction, the sector will remain directionless, and it would
not be possible to make the industry pro�itable. An all-inclusive national power policy is
possible with professionals' input and approval from the CCI (see Box 12.1) and the
parliament. Getting the policy fundamentals right is critical. Otherwise, a positive initiative
in a negative policy environment tends to generate a negative effect rather than simply
no effect.
Energy planning has to be done holistically and not through whimsical projects. Pakistan's
power sector needs coordinated planning to realize an optimal power generation mix
from imported fuels and indigenous resources. In Pakistan, policymaking, in particular
energy policymaking, has always remained under the in�luence of pressure groups within
the system and international �inancial institutions. It has caused enormous damage to
the sector by approving and sanctioning investments in inappropriate projects or
endangering essential projects.
Box 12.1. 18th Constitutional Amendment and Electricity
After the constitution of Pakistan amendment in 2010 (by the 18th Constitution Amendment
Act, 10 of 2010), the rules of business of the federal and provincial governments have to be
taken note of while making a policy and planning in the power sector. At the time of preparation
of the reforms plan in the 1990s and the promulgation of the NEPRA Act, the subject of
electricity in Pakistan was on the concurrent list.
However, since the 18th amendment, electricity has become the subject of federal legislation.
It has been placed in the Federal Legislative List (Part II) for consideration and decision by
the Council of Common Interests (CCI). The provinces are empowered to levy electricity
consumption taxes and determine the tariff for its distribution within the province. But it did
not remove the federal powers to do the same because the exercise of such powers by the
provincial government is not mandatory but optional.
135
Power Sector
A federal government can legislate to the maximum extent of its powers. However, the federal
legislature cannot legislate without substantial consultation with the respective provincial
governments. The CCI is empowered after the 18th Amendment Act to do substantial
consultations
The root of the CD challenge can be traced back to the early 1990s when long-term and
unviable contracts were made with private investors on the advice of the WB without
probing their long-term impact. The same mistake was repeated over the years, trapping
the sector and economy.
To overcome the governance and �inancial problems, the government, under pressure
from international �inancial institutions (e.g., WB and ADB), started the reform process
in the sector. After over three decades, progress has yet to be achieved; the sector is worse
off, facing even more challenges. Once again, the WB and ADB are providing technical
assistance to the power sector. It is time to let the local people do the necessary reform.
12.4. ESTABLISH A POWER COMMISSION

For a sustainable power sector, deep structural reforms are crucial. For informed policy
advice on these reforms and to monitor the restructuring process, the GOP should establish
an independent Power Commission. The Commission should comprise hardcore power
sector professionals, i.e., renowned generation, transmission, distribution engineers, tariff,
and regulatory experts for developing and issuing power sector advisories. There should
not be any political appointees. The advisories of a Power Commission should be made
mandatory for the Power Division and PSCEs, to implement. The Commission would
prepare a sector progress report and present it to the Parliament bi-annually for discussion
and review. The Commission would be formed initially for one year. The time may be
extended provided noticeable positive outcomes, otherwise dismantled (details in
Appendix D).
12.5. POWER SECTOR REVENUE RECOVERY PLAN

The power sector has been held hostage by continuously increasing �inancial losses due
to high technical and administrative losses and low bill recoveries for the last �ifteen
years. Apart from being unable to effect full targeted recovery of the current bills, the
earlier build-up is added to each month. The reason being the recovery activity is never
comprehensively taken. The emphasis remains on preventing the build-up of the default
�igure alone, which is also not achieved; a negligible amount gets recovered from the
earlier defaulters.
136
Power Sector
▪ A plan to recover Rs. 300-500 billion in the next six months must be prepared
and implemented. After that, a similar plan for the remaining amount in the
next 12 months. Later, the DISCOs should be made to fend for themselves.
▪ The government must set targets before the plan is implemented.
▪ The current legislation is de�icient. Thus, the Power Commission (with the
support of power sector entities) would draft a summary to recommend changes
in the Electricity Act of 1910 (rati�ied by the Parliament) to strengthen the
recovery process_ enabling the DISCOs to recover legitimate revenue on the
fast track and without protracted legal processes.
▪ Senior power sector professionals (maximum two for more problematic DISCO)
must be hired for six to twelve months, with an extension on a need basis.
▪ Their job would be to implement and monitor the recovery roadmap on the
ground.
▪ Based on the quantum of receivables, the Commission would set the targets for
these experts for each DISCO (20% to 25% of all defaulters).
▪ The CSDs would be responsible for the DISCO recovery. The experts would
oversee the recovery process.
More details are in Appendix E.
12.6. TECHNOLOGY AND POWER SECTOR
Power companies in Pakistan face a range of challenges that can only be handled by
transforming their operations and business models. They must develop/ modify their
business models to adapt to changing global environments and local needs.
They need to develop a marketable approach targeting different consumer categories

and providing them with high-value and competitive services. Besides, ensuring
infrastructure up-gradation and management to become resilient against environmental
and socio-political challenges.
Power companies need to rely on IT and adopt innovative managerial techniques. They
must undertake technological changes at the earliest.
137
Power Sector
▪ Solutions such as pre-paid metering must be brought to the fore for commercial
and operational ef�iciency and to cut down expenditures46.
▪ AMI, up-to-mark distribution/power management systems, speci�ically SCADA

and 4th generation communication modules, will assist in utility operations if
implemented timely. Two-way communicating AMI can help the power system
update operations, assuring the customer of proper billing. On the other end
will assist energy ef�iciency and conservation levels.
Box 12.2. Conventional Vs Smart Pre-paid Meters
Conventional electricity meters only have one-way manual communication between the users
and the utility providers, requiring personnel to record the consumption manually and issue
a bill. That leads to inef�icient billing, loss of data and human errors.
Smart meters can eliminate the role of physical personnel on the ground for monitoring and
meter readings. It can increase load management ability during peak hours and effectively
manage load forecasting and the power grid.
Pre-paid (or pay-as-you-go) smart meters are spreading rapidly across developing countries.
Evidence suggests that consumers switching from post-paid monthly bills to pre-paid meters
reduced their electricity usage drastically. From the utility perspective, it allows an ef�icient
bill recovery and controls theft. Thus, helping in meeting the �inancial obligations of the respective
DISCO. Compared to a centralized conventional billing system, pre-paid metering linked to the
DISCO level billing system enables the fair and transparent �low of information and revenue.
In Pakistan, illegal electricity connection or meter tampering, lack of management, corruption,

poor infrastructure, poor monitoring system, and poor staff training are common. Pay-as-you-
go smart meters can resolve these power sector challenges signi�icantly.
46 Especially for low-usage customers where meter reading and subsequent (post-paid) billing entail
high expenditure, sometimes even more than the usage/billing at these sites).
138
Power Sector
Box 12.3. Challenges of Pre-paid Smart Metering System

in Pakistan
▪ Resistance from DISCO employees due to the fear of downsizing non-technical personnel,
i.e., meter readers, and the fear of losing a back door income.
▪ Lack of technical expertise at the DISCO level to implement and the lack of information at
the government level to select the best suitable pre-paid metering type.
▪ On the consumer end, fear of an increase in tariff or subsidy elimination.
▪ The internet-based purchase of electricity requires speci�ic technical expertise for designing,
installing, and managing the backend operations of the pre-paid metering system, which is
currently missing.
Under the power sector reforms agenda, several countries have introduced pre-paid metering
and gained signi�icantly in increasing electricity use ef�iciency and reducing commercial losses.
Compared to a centralized conventional billing system, pre-paid metering linked to the DISCO
level billing system enables the proper and transparent �low of information and revenue. Yet,
migrating from the conventional standalone post-paid metering system to the new smart pre-
paid metering system would require initial capital investments.
▪ The most critical challenge in implementing the pre-paid metering system in Pakistan is the
availability of �inancial resources for developing an IT infrastructure at the DISCO level and a
two-way communication system, importing, or manufacturing meters, vending points, etc.
The cost can be reduced/ managed through various options, as in Figure 2.4 in Chapter 2. Start
implementing the pre-paid metering system from a few loss-making feeders in utilities like
PESCO, SEPCO and HESCO, where GSM technology is also available. Later extend it to all
consumers.
▪ A future with robust IT and Arti�icial Intelligence (AI) based content ensures
apt supplies, usage in line with the contracts (between the utility and its
consumer base), facility of Time of Difference (TOD) tariffs and allied use. It
increases the ability to share Demand Side Management (DSM) gains between
the utilities and its clientele, restricted or complete stoppage of supply due to
non-payments.
▪ The AI component would further improve the service and assure predictability
of supplies etc. The IT support systems have the potential to ensure consumer
discipline, stop misuse of power supplies, safeguard equipment and lastly be
able to inhibit illegal abstraction of energy.
▪ With technology, the current load suppression model of tariff formulation will
also give way to a rational tariff
139
Power Sector
▪ The extensive use of IT / AI-based asset management tools will help convert
the Pakistan power sector into a robust system. Consequently, assuring
continuous, standard, and affordable power for the people47.
▪ While upgrading the distribution system, moving distribution grid stations

and NTDC sub-stations underground will help mitigate accidents and increase
system resilience. The beginning work may also start from large urban centers_
clearing the city landscape.
▪ With the addition of UHV and DC transmission lines, the present loss level will
reduce substantially. Providing converter stations at appropriate locations
would ensure alternating current use for distribution.
▪ On the transmission side, upgraded design con�igurations for power transmission

with high voltages can reduce system losses and stability.
12.7. INDIGENOUS ENERGY FOR FUTURE
There is a need to optimize the generation portfolio. There is a need to monitor, forecast,
and manage a complex mix of small to large generation units. Due to the highly volatile
global energy market, distributed generation using localized renewable energy sources
is gaining traction worldwide.
The world is racing towards increasing energy productivity through ef�icient use, renewable
energy sources, and related technology. Pakistan also needs to shift to enormous indigenous
energy potential. It is vital to induct the system of advanced storage batteries – necessary
to stabilize intermittency content in the system on account of high ARE content and to
arrange balancing of the system to counter emergency shortages. If made, these additions
would be revolutionary in shifting from the current reliance on imported fuels.
▪ Distributed generation (renewable energy sources) offers a solution to the retail

competition. It is a better option compared to mega renewable energy projects.
▪ As net metering and solar power systems (up to the industrial scale) move ahead,
irritants need to be cleared in this regard rather than adding more hurdles to it.
47 Continued political interference in the sector has compromised the attainment of these goals.
140
Power Sector
▪ SBP may thus formulate a policy for commercial banks to encourage further
and take the renewable energy projects as security/collateral for providing
loans for ARE projects in the private sector. The current portfolio for such loans
should also be enlarged to cater for the demand.
IGCEP (2021-30) set the target for variable renewable energy sources at 12 per cent
by 2030. It is below the target of 30 per cent set in Pakistan's Renewable Energy Policy
2019. Wind and solar are quickly becoming the cheapest sources of generation technologies,
and Pakistan has enormous potential for these.
▪ Generation of power needs a quick relegation of polluting thermal power while

increasing wind, solar, hydro, and other alternative energy sources to more than
70% of the power generation facilities by 2030.
In the initial stages of renewable energy, these have little impact on grid stability as they
could be either connected or disconnected because of their low penetration level. But
with its increasing share, it creates grid stability and reliability issues.
▪ A grid that relies on distinct types of renewables, e.g., solar, wind, and hydro,
can handle intermittency issues and experience less generation volatility. A
uni�ied control system across resources results in the utilization of generated
power more effectively as the balance between the sources is achieved.
IGCEP (2021-30) has included hydro among renewable sources. It is planned to increase
from 9873MW in 2021 to 23035MW in 2030. Hydro is the cheapest energy source in
terms of levelized cost. It is encouraging to see several small hydro projects in the plan.
However, in the committed hydropower projects, there are several big dam projects. Large
hydro projects come with risks. That makes the implementation of the proposed plan
uncertain. For example, the cost of the Diamer Bhasha Dam was US$ 12.6 billion in 2008.
It has now increased to US14 billion (a conservative �igure). It is feared that a dam could
require twice its initial �inancial estimates because of in�lation, debt servicing, local currency
depreciation, and environmental externalities costs.
141
Power Sector
In energy planning strategies, the focus on indigenous resources has always been at the
forefront, but unfortunately, not timely implementation. The construction of the Diamer
Bhasha dam has already been delayed due to a lack of �inances and con�licts (cited from
Malik and Ahmad, 2022). One can only hope that the committed hydro projects are
complete in time, unlike Neelum Jhelum. Only timely completion of these hydropower
projects can avoid cost escalation to some extent and enhance cheap electricity generation
capacity48.
Another issue worth considering is net hydel pro�its (NHP). The issue of NHP has plagued
the relationship between the provincial governments, particularly Khyber Pakhtunkhwa
and the federal government for over 40 years. There is a need to re-examine the issue
based on changing power sector dynamics and constitutional legalities and solve the
matter permanently.
Box 12.4. Net Hydel Pro�its (NHP) Controversy in Pakistan
NHP is the money paid by the federal government to provinces for the electricity produced
from hydropower stations within their boundaries. The constitution of Pakistan guarantees
the right of NHP for the federating units. Article 161 (2) says, “the net pro�it earned by the
federal government, or any undertaking established or administered by the federal government
from the bulk generation of power at a hydro-electric station shall be paid to the province in
which the hydro-electric station is situated”. An explanatory clause is, “for the purpose of this
clause, ‘net pro�it’ shall be computed by deducting from the revenues accruing from the bulk
supply of power from the bus-bars of a hydro-electric station at a rate to be determined by the
council of common interest, the operating expenses of the station, which shall include any
sums payable as taxes, duties, interest or return on investment, and depreciations also elements
of obsolescence, and over-heads, and provision for reserves”.
In 1986, the GOP constituted a committee under Mr. A G N Kazi (Deputy Chairman of Planning).
It decided that the net pro�it would be computed based on what the consumers pay. The
calculation would be worked out through backward computation by deducting the T & D cost.
In January 1991, the CCI endorsed the recommendations. However, over the years, the issue
of NHP continued to plague the smooth working of the constitutionally protected arrangement
regarding the transfer of NHP to provinces. It is because of the weak balance sheet of WAPDA
that it could not pay NHP fully and on time. It is pertinent to mention that WAPDA’s balance
sheet has suffered due to inef�icient and high-cost thermal power plants inducted into the
power system over the years.
Source: Government of Pakistan (2019)
48 We started Neelum-Jhelum from Rs 18 billion and around Rs 500 billion. The escalated cost was paid
by consumers in the form of ‘Neelum-Jhehlum Surcharge’ in their electricity bills for more than a decade.
142
Power Sector
The world is moving from centralized energy management to decentralized management,

storage technologies, and micro & smart grids. Tailor-made renewable energy solutions
provide support and an alternative to centralized grids, while battery storage can enable
a 24/7 power supply. Smart grid technologies can enable higher levels of renewables in
electricity systems by making the system more �lexible, responsive, and intelligent. Smart
grid technologies provide the means to integrate these renewables cost-effectively.
▪ Move from centralized energy management to decentralized management;

storage technologies; micro & smart grids. There is also a possibility of shutting
down some grids and making way for renewables.
The localized energy grid solutions offer energy independence and ef�iciency. The
government must support distributed energy projects.
Private investment, particularly FDI in renewable technology, is a growing phenomenon.

Pakistan may also explore this option through. Public-private partnerships can also be
explored and encouraged. A comprehensive energy development plan gives global investors
an idea of how much the market for renewables will grow.
▪ Continuity and consistency of rules, processes and, above all, a consistent policy
is necessary to attract not only foreign but local investors.
▪ Make a level playing �ield for renewable technologies.
▪ Prioritized and guaranteed access to the national grid.
▪ The process for approving power plants, from submitting the proposal to
obtaining the approved power purchase agreement, is quite long. There is a
need to minimize administrative and regulatory burdens.
143
Power Sector
Box 12.5. Micro & Smart Grid Vs National Grid
National Grid extracts electricity from power plants over long distances via T & D lines. Delivering
electricity from distances is inef�icient, with losses of around 8-15% in transmission. The
introduction and widespread use of several sensitive electrical and electronic gadgets in
economic activities have increased the importance of electricity quality and reliability issues.
A reliable power system requires an appropriate grid infrastructure to be renewed and
maintained according to ef�iciency criteria. Implementing microgrid technologies will allow
enhancements to the operations of the existing infrastructure, improving energy ef�iciency and
supporting the development of new power market models based on distributed generation (DG).
DG and integration of distributed energy resources in the form of microgrids can signi�icantly
improve power quality and reliability to suit the customers' needs.
In Pakistan, the main challenges with the national grid are:
▪ Optimization of grid infrastructure.

▪ Decades of under-investment_ T & D operators in Pakistan needs to update their grid
infrastructure and upgrade their monitoring, controlling and operating technologies to
meet new challenges and technologies.
▪ Effective demand management.
▪ Infrastructure availability to areas with no access to electricity.
▪ Integration of energy storage devices and manage volatile renewable generation to mitigate
the risk of unplanned generation capacity losses.
With the CD of Rs 2.3 trillion, high system losses, huge capacity charges and dependence on
imported fossil fuel, the energy cost is 30-40% higher than its regional counterparts. Inadequate
T & D infrastructure are adding fuel to the �ire. Over 40 million people in Pakistan are not
connected to the national grid, while grid-connected consumers face power outages daily. A
microgrid can be a viable option to support power companies to meet increasing challenges.
Yet, a microgrid is not without challenges for remote areas with no access to electricity because
of:
▪ High installation costs

▪ Lack of technical knowhow in local communities
▪ Lack of communication and transmission infrastructure
▪ Infrastructure availability to areas with no access to electricity.
Management and operational issues
For such areas, the microgrid can be an arrangement provided the abovementioned challenges
are handled through government support, public-private partnerships, or local initiatives.
However, a microgrid can give support to the national grid. It can increase reliability and
reduce power outages.
144
Power Sector
All new capacity additions must be below the average cost of current production. Let the
market dictate the new capacity additions; they should not be prescribed. Let the market
decide on energy sources for the future.
Given the current capacity (installed and in the pipeline), the level of coal-�ired power
would quadruple within the current decade; the present resolve to convert local coal to
gas or diesel would come to naught as there is no champion to ensure so. Besides, providing
clean technology for coal-�ired generation would be acceptable to a limit.
▪ Nuclear energy49contributes and will do so in the future, along with heightened

security standards. The only thing that needs to be ensured is the safe disposal
of nuclear waste. Capacity through innovative techniques must be developed to
dispose of nuclear waste.
▪ Likewise, generation plants using hydrogen fuel and some little nuclear fusion
generating stations50are another potential to exploit its fuller capacity. All these
transformations in the generation mix would signi�icantly reduce the generation
cost.
12.8. ENERGY CONSERVATION AND EFFICIENCY
Ef�icient energy use can ease production costs, raise factor productivity, and promote
economic growth. Energy demand in Pakistan has grown by about 5% over the years.
25% of the population is still without access to electricity. With rising urbanization, a
growing population, and a burgeoning middle class, energy demand is expected to increase
even more.
49 Pakistan Atomic Energy Commission (PAEC) has done a great job installing and managing 2612 MW
of nuclear power. In the process, the commission has achieved very high plant factors besides providing
predictable power. PAEC's power-generating plans – up to 2025 and beyond (on the drawing boards)
will ensure that such generation capacity will double soon.
50 In a fusion reaction, two light nuclei merge to form a heavier nucleus. The process releases energy
because the total mass of the resulting single nucleus is less than the mass of the two original nuclei. The
leftover mass becomes energy. This technology is ground-breaking and could mitigate the high cost of
generation and fuel transportation issues and glitches..
145
Power Sector
In Pakistan, if we transform our energy system with increased use of renewable energy
in combination with energy ef�iciency and conservation, it will reduce our net energy
production costs. According to one estimate, we can reduce energy demand by 20% to
25% through its productive use in various sectors. The fourth industrial revolution has
empowered us to consume energy more intelligently. 20% savings from ef�iciency and
demand management in Pakistan corresponds to a more than 50% reduction in oil imports.
In Pakistan, environmental and energy legislations do exist that can force a shift to more
resource-ef�icient and low-carbon economic activities. Implementation of existing laws
has been hindered by weak coordination among the relevant institutions and ministries.
Energy conservation and improving ef�iciency in using energy resources via technological
advancements and improvements in institutional quality are critical. Without a complete
shift towards energy conservation and ef�iciency, all efforts will fail.
High-ef�iciency usage requires standard supply; otherwise, the mismatch would result in
considerable damage. As electronics is bound to increase its share of the gadgetry, the
concept of �ilters drawing �irewalls between the utilities and the customers would be
necessary, and so would be the upgraded control systems – for both the utilities and the
customers.
146
Power Sector
BIBLIOGRAPHY
Abbasi, A. H. (2012). Pakistan power sector outlook: Appraisal of KESC in post privatization
period. Sustainable Development Policy Institute (SDPI), Pakistan.
Alahdad, Z. (2012). Pakistan’s energy sector: From crisis to crisis_ breaking the chain.
PIDE Monograph Series, 2012.
Ali, S. A. (2020). The case for energy cooperatives. The News. https://www.thenews.
com.pk/print/607056-the-case-for-energy-cooperatives.
Alternative & renewable energy policy 2019, (Online). Retrieved from https://www.aedb
.org/images/ARE_Policy_2019_-_Gazette_Noti�ied.pdf.
Borenstein, S. (2002). The trouble with electricity markets: understanding California’s
restructuring disaster. The Journal of Economic Perspective, 16(1), 191-211.
Bosio, E., & Djankov, S. (2020) How large is public procurement? Retrieved from https://
blogs.worldbank.org/developmenttalk/how-large-public-procurement
Burgess, R., Greenstone, M., Ryan, N., & Sudarshan, A. (2020) The consequences of treating
electricity as a right. Journal of Economic Perspectives, 34(1), 145-169.
CPEC Power Projects, [Online]. Retrieved from http://cpec.gov.pk/energy.
Fichtner (2020) Wheeling framework in Pakistan. international best practice for wheeling
and recommendations for Pakistan. Report conducted on behalf of Fatima Energy
Limited, Pakistan.
First Power Policy 1994, [Online]. Retrieved from https://nepra.org.pk/Policies/Power
%20Policy%201994.pdf.
Foster, V., & Rana, A. (2019). Rethinking power sector reform in the developing world. The
World Bank, Washington DC. (Sustainable Infrastructure Series).
Government of Pakistan (2019). Report of the committee constituted by cci to deliberate
upon the issue of rates/net hydel pro�it. Planning Commission, Government of
Pakistan.
Grid code 2005, (Online). Retrieved from https://nepra.org.pk/Legislation/6-Codes/6.2
%20NTDC%20The%20Grid%20Code%20June%202005%20with%20Grid%20
Code%20Addendum%20No.%20I%20&%20II/Grid%20Code%202005.pdf
147
Power Sector
Hali, S. M., Yong, S. I. D. W., & Kamran, S. M. (2017). Impact of energy sources and the
electricity crisis on the economic growth: policy implications for Pakistan. Journal
of Energy Tech. and Policy, 7(2).
Haque, N. and Hussain, A. (2021). A small club: Distribution, power and networks in
�inancial markets of Pakistan. PIDE Working Paper 2021:3.
Haque, N. Faraz, N., & Mustafa, G. (2021). Electricity new connection. PIDE Sludge Series
2021:10.
Haque, N., Sattar, S., & Abbas A. (2020). Issues in energy for development. Business
Recorder. Retrieved from https://www.brecorder.com/2020/02/575195/issues-
in-energy-for-development/
Khalid, Z., & Iftikhar-ul-Husnain, M. (2016). Restructuring of WAPDA: A Reality or a myth.
The Pakistan Development Review, 349-359.
Lodhi, A. B. (2014). Costing and tariff setting in power sector of Pakistan. ICMA, Pakistan.
Lodhi, A. B. (2019). Future of competitive electricity market in Pakistan. ICMA, Pakistan.
M. K., &. K. S. (2012). Pakistan’s power crisis: How did we get here? The Lahore Journal
of Economics (17 SE), 73-82.
M. K., &. K. S. (2019). To �ix the economy, start with the power sector. Dawn. Retrieved from
https://www.dawn.com/news/1471526
Malik, A., & Khawaja, I. (2021). Urban resilience and its impact on electricity provision in
Karachi, Islamabad and Peshawar. PIDE Urban Monograph Series, Pakistan Institute
of Development Economics (PIDE).
Malik, A. (2020a). Circular debt: An unfortunate misnomer. PIDE Working Paper Series
2020: 20.
Malik, A. (2020b). Developing electricity market. Naya Daur, 22 November.
Malik, A. (2021a). Corporate Governance in the state-owned electricity distribution
companies. PIDE Knowledge Brief, 2021:40.
Malik, A. (2021b). Independent power plants: History, policy and politics. PIDE P & R on
Political Economy of Private Energy Investments, II(V), May 2021.
Malik, A. (2022a). Privatization of electricity distribution companies_ A way forward.
PIDE Knowledge Brief, 2022: 52.
148
Power Sector
Malik, A. (2022b). Power sector: effective regulation not regulatory burden. PIDE Policy
Viewpoint No. 35: 2022.
Malik, A. (2022c). National Electric Power Regulatory Authority (NEPRA). In Evaluations
of Regulatory Authorities, Government Packages and Policies. Pakistan Institute of
Development Economics (PIDE), 2022.
Malik, A., & Ahmad, U. (2022) Thoughts on Integrated Generation Capacity Expansion
Plan (IGCEP) 2021-30. PIDE Knowledge Brief, 2022:56.
National Electricity Policy 2021, (Online). Retrieved from http://www.mowp.gov.pk/
user�iles1/�ile/National%20Electricity%20Policy%202021.pdf
NEPRA (2020). CTBCM approval by NEPRA. Retrieved from https://nepra.org.pk/licensing
/Licences/CTBCM/2020/LAM-01%20Determination%20CTBCM%2012-11-2020.
PDF
NEPRA State of Industry Report (various Years), National power Regulatory Authority.
NEPRA (2021), IGCEP Approval. Retrieved from https://nepra.org.pk/Press%20Release
/2021/Final%20PR-IGCEP%202021-30-.pdf.
Nicholas, S. (2021). IEEFA: Pakistan new power plan, one step forward and two steps back.
Retrieved from https://ieefa.org/ieefa-pakistans-new-long-term-power-plan-one
-step-forward-two-steps-back/
Nicholas, S., & Buckley, T. (2018). Pakistan’s power future: Renewable energy provides a
more diverse secure and cost-effective alternative. Institute of Energy Economics
and Financial Analysis. Retrieved from http://ieefa.org/wp-content/uploads/2018
/11/Pakistans-Power-Future_December_2018.pdf
NTDC Transmission License, [Online]. Retrieved from https://nepra.org.pk/licensing/
Transmission.php.
PIDE (2020). Framework of economic growth. Pakistan Institute of Development
Economics, Islamabad.
PIDE (2021). Reform agenda for accelerated and sustained growth: Reforms for accelerated
prosperity inclusive development. Pakistan Institute of Development Economics
(PIDE), 2021.
PIDE (2022). Power sector: Effective regulation not regulatory burden. PIDE Policy View
point, No 35: 2022.
149
Power Sector
PIDE Energy Roundtables, PIDE Webinar Brief No 20:2020.

Power Generation Policy 2015, (Online). Retrieved from https://www.ppib.gov.pk/policies
/Power%20Generation%20Policy%202015%20small.pdf.
Power Policy 2002, (Online). Available Retrieved from https://www.ppib.gov.pk/policies
/Power%20Policy%202002.pdf.
Qazi, U., Iqbal, S., Zaheer, H., & Rehman, T. (2020). Prepaid metering: A way forward for
sustainable power sector in Pakistan. Energy Strategy Review. https://doi.org/10.
1016/j.esr.2020.100546
Renewable Energy Policy 2006, (Online). Retrieved from https://nepra.org.pk/Policies/
RE%20Policy%20for%20Development%20of%20Power%20Generation%202006.
pdf.
Report on the power sector (2020). Prepared by Committee for Power Sector Audit,
Circular Debt Resolution and Future Roadmap, Ministry of Energy, Pakistan.
Saini, D. S., & Bhatnagar, J. (2005) North Delhi power Ltd.: Dynamics of change. VIKALPA,
30(4).
Sattar, S. (2020) Circular Debt. Presentation at the PIDE Roundtable Meeting on “Circular
Debt_ an Unfortunate Misnomer,” June 25, 2020
SBP (2019). Evaluating the �iscal burden of state-owned enterprises in the power sector,
special section 2. In The state of Pakistan’s economy. State Bank of Pakistan.
Shah, I, & Khan, G. M. (2017) Cost bene�it analysis of smart metering. International Journal
of Engineering Works, 4(12), 109-112.
Shoukat, A. (2022). Enabling smart metering in Pakistan: FINCA and SBEEC. Retrieved
from https://www.gsma.com/mobilefordevelopment/blog/enabling-smart-metering
-in-pakistan-�inca-and-sbeec/
Stiglitz, J. (2008). Foreword. In Ronald, G. (Ed.) Privatization: successes and failures. New
York: Columbia University Press.
Urooj, A., & Malik, A. (2021). Unlocking energy innovations. PIDE P & R on Political Economy
of Private Energy Investments, II(V), May 2021.
Weare, C. (2000). The California electricity crisis: Causes and policy options. Public Policy
Institute of California, San Francisco, CA.
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Power Sector
APPENDIX A. POWER SECTOR AND ESTABLISHMENT OF WAPDA
At the time of independence in 1947, Pakistan had only about 67 MW of power generation
capacity, including three small hydel plants in northern areas. Power supplies in main
towns were owned and operated by private companies in an isolated mode. Distribution
networks had diverse voltages and frequencies. The provinces' respective electricity and
irrigation departments were responsible for developing the needed schemes in the power
and water sectors.
In 1958, WAPDA was formed to implement the Indus Basin Treaty and develop both the
country's power and water projects. Under WAPDA, power generation capacity continued
to grow steadily. Hydel and thermal plants were inducted. However, consistent power
supply de�icits, massive load shedding, and resource constraints remained the major
bottleneck in the rapid growth of generation capacity, transmission lines and distribution
network.
Box A1. WAPDA's Primary Responsibilities before Power

Sector Restructuring
▪ To meet the electricity demand of the country (excluding Karachi) by installing new power
generation plants, transmission lines and distribution systems
▪ To develop hydro storage projects (dams) to meet the irrigation demand of the country and
install hydropower plants at dam locations
Pakistan Power Sector Generation History
Pakistan’s Power Sector has transformed many a time since its independence in 1947.
Pakistan inherited a generation capacity of only 69MW51, including KESC52 , which
could only reach 119MW by 1958.
WAPDA_ a semi-autonomous organization, was established with duties to generate,

transmit and distribute electricity, along with water resource management for irrigation,
�lood control etc. It became a utility through an amendment in the WAPDA Act in 1959.
WAPDA became a premier organization through its professional approach and with the
help of a dedicated team.
51 (WAPDA statistics, 1958).

52 KESC was incorporated in 1913 as a private corporation under the Indian Companies Act of 1882, as
amended to date vide the Companies Ordinance 1984. The government of Pakistan took control of the
company by acquiring a majority shareholding in 1952.
151
Power Sector
Through hydro and thermal projects, installed capacity reached 1,317MW in 1971. Power
infrastructure development gained momentum in the 1970s and onwards. The installed
capacity reached 7023 MW in 1990-91 with the construction of two large dams, Tarbela
(3478MW) and Mangla53(1,000MW) and some other thermal plants (NTDC, 2011; Malik,
et al., 2009).
The performance of both vertically integrated utilities WAPDA and KESC remained
satisfactory till the mid-1980s; after that, severe constraints in the availability of capital
led to an inadequate generation capacity. Power supply lagged demand resulting in an
excessive electricity shortage, especially for industrial and commercial consumers54. Heavy
financial losses due to undue political interference, poor law and order situation, and
overall operational inefficiency in the sector created the need for restructuring.
Figure A1. Installed Capacity and Electricity Generated
45,000 160,000
40,000 140,000
35,000 120,000
30,000
100,000
25,000
GWh
MW
80,000
20,000
60,000
15,000
10,000 40,000
5,000 20,000
0 0
1947 1958 1960 1971 1981 1991 2001 2012 2016 2020 2021
Installed Capacity (MW) Electricity Generated (GWh)
53 Construction work of Mangla Dam started in 1962 and was completed in 1967, with an installed
capacity of 1000MW.
54 Load shedding up to 30 % of peak demand (NEPRA Annual Report, 2000-01).
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Power Sector
APPENDIX B: WHY THE REFORMS OF THE 1990S FAILED?
For more than two decades, the Pakistan Power Sector has been in the limelight for negative
reasons. What was considered a reform for the good of the people in the mid-1990s is
now a nightmare for the people. The service has deteriorated, management of the sector
has gone awry with the left not knowing what the right is doing, and the consumer-end
tariff is exorbitantly very high. The anecdotal evidence suggests that the power sector is
worse off regarding service reliability, consumer-end tariffs, and overall management
than in the 1990s. Decision-makers know nothing about how the problem would be
resolved. The problem lies in the PD-MoE, owned and operated by non-professionals, who,
unfortunately, don’t know anything about the sector.
Why is it that the reforms of the 1990s failed, and that too on a gigantic scale? Looking
back, we see that reforms took the AEBs out of WAPDA’s Power Wing along with the
generation assets, transmission, and grids, corporatized separately as public limited
companies, only on paper. These companies were never allowed to grow independently.
These new companies lost the status of entities able to recover their unpaid monthly bills
as government revenue or laying distribution and transmission lines under the Telegraph
Act of 1885. It was wrongly thought that the power sector would be out of the governmental
rules and the ensuing audits – and be able to become independent entities enjoying full
autonomy.
Besides becoming a hybrid coming under the ambit of public and private sector laws, the
corporatized entities (present-day DISCOS, GENCOs and NTDC) have become top-heavy
setups. In other words, the reform process started by removing some crucial rights while
highlighting various obligations on paper only.
PEPCO – a private limited company, was formed as a management company. It was

envisaged to be a temporary entity (for three years) to smooth the privatization process
of all state-owned companies (except NTDC), but it didn’t happen.
After unbundling WAPDA as corporate entities, eight DISCOs (later ten), the NTDC, and
the four GENCOs were to have their BODs, as per the Companies Ordinance of 1985 (later
updated to the Companies Act, 2017). While the new companies were in the making,
WAPDA was handed overto the Pakistan Army in 199755 . PEPCO and all companies were
55 During the period 2000 to 2004, the DISCOs were headed by Brigadiers.
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Power Sector
were re-brought under the control of the chairman, WAPDA. To assure a semblance of
corporate correctness, the chairman of WAPDA assumed the role of chairman PEPCO and
handed over the position of MD, PEPCO, to the Member Power, WAPDA. The result was_
business as usual_ a push-pull started, which could not lead to any good.
In September 2007, at the insistence of the donor agencies, the GOP noti�ied the separation
of PEPCO and its management of DISCOs, GENCOs and NTDC from WAPDA by separately
notifying PEPCO’s Chairman and the MD. Slowly, PEPCO also took over the work of
appointing BODs to these companies and then directly took-over operations of the DISCOs.
Later, distinct BODs of all the state-owned companies were appointed, with members
from the WAPDA cadre, the then Ministries of Water & Power and Finance, and wealthy
businesspeople as public representatives.
This resulted in some independence from WAPDA and a greater leaning towards the BODs.
But decision-making remained dominated by PD-MoE. The companies emphasized
procurement in billions and much lessor to enhance ef�iciencies. The losses have ballooned
since then while the revenue collector has plummeted. These remain hidden behind
percentages (Figure 2.3 in Chapter 2).
To add another negative, the GOP set up the GHCL to look after the four GENCOs in the
presence of PEPCO; the avowed policy to disinvest some parts of the government holding
of the power sector. However, it did lead to the shutting up (not even mothballing) of all
publicly owned generation assets (details in Chapter 6). Consequently, assets worth billions
are dormant, no plan to utilize these sites and the allied facilities worth billions to the
advantage of people. The trained human resources of the now shut plants is in the doldrums.
Even the most critical, 1320 MW coal-�ired power plant at Jamshoro, is planned to be
scuttled. They forget that it costs only 60% of the CPEC-funded similar plants with second
-class Chinese �ittings, as against primarily GE equipment at Jamshoro. Overall, GHCL has
been a disaster which only a generalist could conjure.
Considering NTDC, with money, PD-MoE nominated one of its Joint Secretaries with an
additional charge of MD NTDC. It is one of the main reasons for the continued lackluster
working of NTDC. The DISCOs are also headed by temporary, primarily chief engineers
and sometimes GM-level engineers, who look after such work in addition to their substantive
duties.
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Power Sector
In summary, the BODs are not supporting the management of DISCOs, the NTDC and the
GENCOs with their temporary CEOs and the direct control is by the PD. An arrangement
where the PD calls all the shots; non-professionals are profusely making decisions. The
PD has also set up an intelligence cell headed by a retired army of�icer to advise the
Secretary, Joint Secretaries (looking after the NTDC, the DISCOs and the GENCOs) and
placed on a few BODs for further steering the sectoral operations.
DISCOs are relying on revenue-based load shedding to improve their ef�iciency arti�icially.
For instance, currently, HESCO, SEPCO, QESCO, PESCO, and the TESCO are resorting to
rationing of electricity supplies in their challenging areas_ where recovery of revenue is
dif�icult or where illegal abstraction of electricity is rampant. Consequently, lesser supply
to these areas results in improved line losses and revenue collection on a percentage
basis (details in Chapter 2).
As service diminishes, tariff increases, circular debt escalates, and the sector suffers for all
intents and purposes, it can safely be concluded that Power Division’s sectoral capture is the
major challenge. No reform – with any nomenclature, can succeed with the generalists
steering the same.
Now, PEPCO has been revitalized as PP&MC. It is in the process of being settled in Islamabad
as an appendage to the PD. Soon we will have the member (energy), Planning Commission,
the PP&MC, CPPA(G), NTDC and the donor agencies (WB, ADB, KFW, JICA and the USAID)
once again planning for the power sector. A shift of PP&MC to Islamabad_ changing its role
from a management company to an arm of the PD is not much of a solution.
In other words, the capture of the power sector continues. Additionally, under the present
arrangements, the possible offering of DISCOs on short-term management contracts, the
implementation of CTBCM and the establishment of the multi-buyer system (against the
current single-buyer model) becomes impossible.
The power sector has been poorly managed since it was taken out of WAPDA. Now stands
without sectoral expertise and knowledge, which WAPDA used to have.
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Power Sector
APPENDIX C. SENIOR MANAGEMENT CHALLENGES
The Pakistan Power Sector is beset with many management issues. For instance,
▪ Chairman WAPDA, a non-professional or a generalist.

▪ Members of WAPDA authority, although those holding the position of Member
(Power), Member (Water) and Member (Finance), are junior-level professionals,
posted temporarily (with look after charge) in addition to their substantive
positions. These postings ensured that the related of�icers remained subservient
to the competent authorities.
▪ Non-professional board members of ex-WAPDA companies, against the criteria

of the SECP.
▪ Arbitrary postings by the Power Division (PD) to �ill management posts (CEO)
of DISCOs, NTDC and the GENCOs (inclusive of the GHCL) on the retirement of
the earlier stop-gap incumbents.
These have severe rami�ications for the ef�iciency of WAPDA and ex-WAPDA companies.
For instance, in ex-WAPDA entities, the incumbents to the position of CEOs or on the BODs
immediately enter the hegemonistic mode to cover up for their non-professional or weak
professional experience. These individuals often overturned tried/set procedures to prove
that they knew the job; it damages the sector. After the expected setbacks, the hegemonistic
mode gets converted into the amazement mode. They also started to understand that the
entity, especially WAPDA and the Ex-WAPDA companies, have a long history of existence,
management structures, accountability modules and speci�ic identity.
For example, take the army’s management of WAPDA between 1998 till 2004. In the �irst
year, all set procedures were overlooked or overturned. In the next six months, the regime
was intimidated by the established procedures in WAPDA. Then incumbents entered the
learning mode and tried to learn what WAPDA professionals had learnt in their 20-30
years of service in six months or so. As a result, the management in the power sector got
burdened with issues and resulted in many �lawed decisions; the ef�iciency and ef�icacy
of the sector got hit.
That was the most damaging period for the powers sector because the generalist / non-
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Power Sector
professional had to show that he was better than the earlier ones. Via fudging of �igures,
comparisons were crafted. These all got debunked with the posting of professionals to
these positions.
At present, again, the situation is critical as experienced professionals have been sidelined.
Most positions have been handed over to the generalist or people with little experience
in the power sector. Moreover, the government’s thinking excludes sector professionals,
while ex-pats with spurious experiences are given preference as a panacea. The same
thought process is applied in selecting members of BODs of corporate government entities.
The BODs have members with irrelevant experience, even people having severe con�licts
of interest.
Political in�luence in all appointments is obvious; the minority selection based on merit
has not been able to stay for extended periods. In some cases, subsequent soul-searching
by the selectors highlighted the earlier wrongful selections. Yet, the replacements were
even worse. In most instances, the governments resorted to just handing over the vacant
slot as an additional charge to a generalist.
So much has been the misuse of this short-time solution that ministry of�icials had held
necessary power sector charges for years_ detriment to the company. Those granted
charges did not even accord it any importance and carried on while sitting mainly in
Islamabad, even calling the BOD meetings in the capital. Besides resulting in mismanagement,
it is the reason behind the creation of cliques in the PSCEs, in�luencing management.
All PSCEs are directly controlled and governed by the generalists of the PD and unprofessional
boards. Thus, resulting in a stalled sector with a circular debt of more than Rs. 2.3 trillion,
a default amount of more than Rs. 1.6 trillion (to be recovered from the defaulting power
sector consumer base (governmental and private sectors), continued load shedding and
poor service to the consumers.
Selecting Senior Management
With continuous mismanagement, permanent damage has been done to the fundamental
structures relating to regulatory and corporate affairs, procurement modules56, posting
56 Procurement activity has been permanently damaged. The local engineering industry (set by great effort
and support of WAPDA during 1975-1995) has nearly done. Unknown foreign companies are the leading
suppliers of intricate equipment; MNCs have left without leaving behind any successors, e.g., Siemens.
The sector relies on designs and non-specified equipment, illegal naming of assemblers as valid manuf-
acturers, hijacking the AMI / RMS systems by hardware suppliers against the requisite IT integrators, etc.
157
Power Sector
and placement for various positions, succession procedures, HRM & HRD process, etc. In
other words, the entities subject to such abuse have been relegated with time.
The power sector is highly technical. It is transforming quickly and needs engineering
expertise with IT modules to counter various problems besetting current operations.
The senior managers must have the ability to adjust and innovate.
A professional can quickly adapt to new realities and completely transform in the least
possible times, which is impossible for the generalist. He has a deep insight into the
dynamics of the core responsibilities and the ability to dip into current and future trends.
He is equipped with knowledge of the weaknesses and strengths of the speci�ic sub-sector
and would be able to build upon the existing expertise. That is, to enable the organization
to jump even higher by breaking earlier constrictions and barriers and change management
in a structured manner. He can arrange conversion to the next generation of technologies.
For instance, the CEO of a public sector corporate entity is responsible for the overall
management of company operations and for ensuring the achievement of the company’s
service and revenue targets. To meet higher operational performances, he will set targets
and formulate plans with particular emphasis on load management, loss reduction, theft
control and signi�icant augmentation/improvement of the distribution network and
services to customers in a new paradigm of customer-friendly culture. He will ensure
adherence by the company to NEPRA performance standards and meet relevant regulatory
and operational requirements.
The management needs to comprehend the mission statements and objectives; therefore,
he must be creative and have the inbuilt capability to adapt or counter-force, assailing
the primary core responsibilities of the state-owned company. Besides, he must understand
national policies. Therefore,
▪ A pro-active, results-oriented professional with established credibility and

performance record who could take the above challenging assignment is
required.
▪ The candidates must have strong leadership, interpersonal and communications

skills with a high drive for performance targets.
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Power Sector
▪ Quali�ication and experience_ preferably to be a professional engineer registered

with the Pakistan Engineering Council (PEC) or a senior power utility manag-
ement expert. Additional engineering and management quali�ications and
experience in power utility operations are considered an added plus.
▪ A minimum of 20 years of experience, with at least �ive years in a senior

management position, is essential.
The current practice allows for the senior slots to increase. The GOP, through its PD, starts
the process by drafting advertisements and getting approved. There is no set format. A
matrix of some of the advertisements is in the Table below. A review of this Table reveals
a difference in the experience, educational and maximum age criteria. This aspect alone
depicts the confusion in the sector.
The advertisements reveal that the BODs (including the PD) are oblivious to the sector’s
experience requirements and dynamics57. At the same time, oblivious to the earlier failures,
the advertisements ask for a minimum of 15 years of experience without being in the
power sector. Strangely, the experience of the MD, PP&MC (Power Planning & Monitoring
Company), initially 15 years, was quickly changed to only 12 years. For this post, the
minimum experience must be at least 25 years and that too of the power sector itself, as
�ixed by the SECP in its �it and proper criteria for CEOs of SOEs.
57 Between 1958-1981, under WAPDA, all employees were civil servants under essential services. It led to the
promotion based on the principle of seniority cum fitness. It was fair in the Pakistani context to avoid political
interference. As a downside, it led to the ouster of many stars_ as the seniority comes late in service and soon
the senior is up for retirement. The professionals of the ex-WAPDA corporate entities are experienced and in
their late-50s. The rule for the top slot, i.e., CEOs, cannot be capped at less than 60 years; otherwise, the sector
will lose access to the most experienced.
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Power Sector
Table A1. Matrix of Job Advertisements
Minimum
Required experience Minimum

Maximum
Date of years (Sr.
Position Company age of
Publication (Break-up) Mangt
Applicant
Level)
Years Speci�ically General
Engineering - Or
Power Utility Non -
Speci�ic
08/11/2021 Managing PP&MC 15 15 Years 5 Years No upper age

Last date Director �ixed
21/11/2021 Managing PP&MC 12 12 Years 5 Years No upper age

Director �ixed
08/11/2021 Director PP&MC 15 15 Years No upper age

Last date General �ixed
20/12/2021 CEO MEPCO 20 10 Years 10 Years 3 Years No upper age

Last date �ixed
24/01/2021 CEO LESCO 20 10 Years 10 Years 3 Years No upper age

�ixed
Within 15 days CEO FESCO 20 10 Years 10 Years 3 Years No upper age

of publication �ixed
17/01/2021 CEO GEPCO 20 10 Years 10 Years 3 Years No upper age

�ixed
21/01/2021 CEO MEPCO 20 10 Years 10 Years 3 Years No upper age

Last date �ixed
19/01/2021 CEO SEPCO 20 10 Years 10 Years 3 Years No upper age

�ixed
17/01/2021 CEO IESCO 20 10 Years 10 Years 3 Years No upper age

�ixed
23/01/2022 CEO FESCO 20 10 Years 10 Years 3 Years 60 years
13/01/2022 DMD NTDC 15 15 Years - - 58 years
04/03/2022 CEO Public 20 20 Years 20 Years 5 Years 62 Years

Sector
03/02/2022 CEO GHCL 20 - 20 Years 7 Years 62 Years
13/02/2022 RECTOR PIEAS 20 20 Years - 5 Years 60 years
13/02/2022 CEO GEPCO 20 10 Years 10 Years 5 Years 60 years
13/02/2022 CEO PIAC 20 20 Years - 10 Years 62 Years
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Power Sector
Then comes the selection process itself. Who would shortlist and then interview the
applicants? The best would be for the existing BODs of the PSCEs to task their HR
Committees to shortlist the applications based on a set format. Once the shortlisting is
complete, just like FPSC, the BODs would have to invite sectoral experts or subject
specialists to be part of the selection interviews58.
In short, selecting the right person(s) for the sector is beset with problems: below-par
understanding of the sector, its obligations, the dynamics, and the underlying currents.
No one has ever undertaken the required SWOT analysis. Once the prerequisites/
requirements are laid-out and accepted, another issue to contend with in the present
pre-conceived notion is that the in-house resources cannot deliver. There is a need to
understand that the best candidate would be from within the Pakistani power sector
instead of the private sector or amongst the so-called ex-pats.
Corrections from top to bottom is required. The present lot, including the BODs, the CEOs,
and the rest of the senior management, must be replaced soon.
58 In the selection process of the MD, PP&MC, the selection board comprised of the Secretary (PD), Additional
Secretary (PD) (with a look-after charge of PP&MC), NESPAK employee, earlier Joint Secretary (PD), and a
private sector personality with experience of being on the BOD of MEPCO. None of these persons qualifies to
be in the selection process.
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Power Sector
APPENDIX D. POWER COMMISSION
The unbundled power sector companies (especially NTDC) are now without legal support.
Earlier, it was available through the Revenue Acts and the Telegraph Act of 1885 – enacted
solely to support laying lines for the public good, etc. The situation can be improved
through the support of power utility practitioners, the Power Commission, comprised
of hardcore eminent sectoral practitioners.
Commission’s Terms of reference (TORs)
▪ To monitor the implementation of re-structuring of the Power Sector.
▪ Prepare the initial sectoral diagnostics report with broad outlines for the best
possible operations.
▪ Structure a revival roadmap with set milestones and a timeline.
▪ Suggest ways to stop the illegal reaping of the political economy of the sector
and the threats posed by the present level of customer indiscipline.
▪ Review the existing policies.

▪ Prepare long-term strategy and policy documents.
▪ To provide solutions to the �inancial viability and economics of ending the

revenue-based load shedding.
The commission would be answerable to the Prime Minister59. Its members must be hard
core power sector practitioners who have headed sectoral entities_ preferably those
considered leaders in the sector. The commission, comprised of six to eight professionals,
would place the power sector operations under their magnifying glass, monitor, and then
advise appropriate quarters to correct wrongful processes. The commission would also
offer advice in the implementation process. Stakeholders would be obliged to accept the
advice; otherwise, the PM’s secretariat would take the delinquents to the task.
Power Commission may be mandated for one year after its ef�icacy can be gauged.
59 The Cabinet Committee on Energy (CCOE) formed earlier cannot be the panacea for sector ills. It is a
coordinating body and does the preliminary work for the Cabinet. In many cases, CCOE placed its TORs on the
back burner by trying to run the sector.
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Power Sector
APPENDIX E. POWER SECTOR REVENUE RECOVERY PLAN
Preamble
The Pakistan power sector has been facing a crisis since 2006 with no reduction in the
of�ing. Poor �inancials of the power sector exacerbated the power shortages of 2006-07.
Even after the signi�icant addition of MWs from 2015 to 2017, the sector is held hostage
by the more aggravated �inancials (high technical and administrative losses coupled with
low bill recoveries).
Apart from being unable to effect full targeted recovery of the current bills, the earlier
build-up is added to each month. The policy to pass on most inef�iciencies to the compliant
power consumers did not help much but disincentivized ef�iciencies. A little insight into
current DISCO affairs reveals that recovery activity is never comprehensively taken. The
emphasis remains on preventing the build-up of the default �igure alone, which is also
not achieved; a negligible amount gets recovered from the earlier defaulters.
The whole chain of of�icers responsible for recovery is mired in billing issues60 , leading
to a slight improvement in only the current billing recovery. Yet, there is no effort/ activity
towards improving the recovery from earlier defaulters.
The government must �irst tackle the ever-deteriorating �inancial situation of the sector
before any restructuring. A plan to recover Rs. 300-500 billion in the next six months must
be prepared and implemented. After that, a similar plan for the remaining amount in the
next 12 months. Later, the DISCOs should be made to fend for themselves. The government
must set targets before the plan is implemented. All necessary changes required in the
existing legislation to strengthen the recovery process must be made before executing
the recovery plan.
Power Sector Revenue Recovery Plan (PSRRP)
The Power Commission may be tasked to execute this plan, where the Commission chair
would act as the coordinator. Senior power sector professionals would be hired for six to
60 The chain starts from the CSD at the DISCO HQ, the Director Commercial at the HQ, the Director
Commercial at the circle level, the Revenue Officer at the (Executive Engineer Office (XEN)’s level and
lastly, the meter reading supervisor at the sub-divisional level.
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Power Sector
twelve months, with an extension on a need basis61. Their job would be to implement and
monitor the recovery roadmap.
The coordinator would be responsible for giving targets to these experts (maximum of
two) for each DISCO, based on the quantum of receivables from these distribution
companies_ details of which are available in published statistics. To set the targets, the
coordinator would prepare lists of all big defaulters (probably 20% of all defaulters),
including Federal and Provincial government entities. All this information, in detail, is
available with the DISCOs and the Power Information Technology Company (PITC).
The coordinator, via these experts, would require the DISCOs to immediately prepare
individual account sheet(s) of all defaulters; currently, individual account sheets are
not available to the sub-divisional staff, primarily responsible for the recovery. This
record would assist in actual recoveries as the default amount would be listed herein
(and could be provided to the defaulter if they demand). The coordinator will �ix the
targets based on 30-day rosters.
The plan would target the low-hanging fruit in the �irst stage, i.e., the running defaulters
(those in default but still receiving power supply). Under the plan, the DISCO will
disconnect all running defaulters within ten days after the Revenue Recovery Plan's
commencement. The DISCO will only restore the connection once the default amount is
fully paid; only those premises will be exempted from the action where court injunctions
are in force. Similarly, the DISCO will not disconnect the defaulters where the department
/ competent authority has set aside the default amount.
The DISCOs, through their Superintendent Engineers (SE) (business units), would be
obligated to immediately take up the vacation of stays etc., from the courts (higher
courts), if needed and then assure recovery of the default amounts. The services of the
Company Legal Of�icers (CLOs) must be made available to the SEs as per the erstwhile
performance contracts signed earlier between the then Ministry of W&P and DISCOs.
That would also make the CLOs responsible for recovery along with the SEs/Executive
Engineers (XENs)/Sub-divisional Of�icers (SDOs).
61 It is crucial as local officers and functionaries of DISCOs face difficulties in recovery, especially from influential
people. They do the job only when they can easily qualify responsibility on HQ officers or Ministry.
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Power Sector
The current legislation is de�icient in relating to the recovery process after the corporatization
of WAPDA. Thus, Power Commission must be tasked to draft a summary to recommend
changes in the Electricity Act of 191062, enabling the DISCOs to recover legitimate revenue
on the fast track and without protracted legal processes.
In case of a setting-aside administrative order being in force, the of�ice issuing the order
in the �irst place would be obligated to give a show-cause to the customer in default,
receive the reply to the same and then issue a speaking order deciding about the fate of
the default. It all must be done in 10 days. If the DISCO fault is evident, e.g., wrong billing,
it will remove the default amount immediately and starts an inquiry against the negligent
DISCO of�icer. On the other hand, if the bill is correct, the DISCO would disconnect the
defaulter's premises at once. The DISCO would reconnect the premises only after the full
payment of the outstanding invoice.
The governmental default would be tackled by �irst approaching the Deputy District
Of�icer (DDO) concerned at each station/city in a particular DISCO, giving notices of
disconnection via the next higher of�ices, wherever located. Then, taking up actual
disconnections of non-essential premises �irst and then others too.
There is a requirement to clearly distinguish between the recovery of current billing each
month and earlier default amounts. Once this distinction is made, then the actual ef�iciency
of any entity / DISCO would be seen, and the Power Commission would be able to monitor
and report the recovery campaign.
The DISCOs (over the years) have overlooked the speci�ic duties of �ield staff_ opting for
a mix and match of tasks from maintenance, new connections, disconnections, reconnections
and even meter readings to the same supervisors. This division of duties keeps them
happy, allowing them to evade accountability and concentrate on jobs getting illegal gains,
e.g., bribes.
The experts would visit the DISCOs HQs (designated for recovery) _ meet the Customer
Service Director (CSDs) and other relevant staff, check the recovery process, visit the
problematic circle's of�ices to understand their process and upgrade the same where
required, and then oversee the recovery process. As all the experts would have held senior
62 To be made available through an Act ratified by the Parliament.
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Power Sector
positions in the past in the sector, they would face no problem from the circle of�ices in
implementing the plan.
Federal & Provincial support to DISCOs is of the most importance – especially when the
DISCOs are service providers alone.
Box A2. Revenue Generation Task Force (RGTF) Report
An RGTF was set up in 2010. It came up with a comprehensive report, followed as a manual till
2011 when it was relegated to a signi�icant loss for the Power Sector. This manual was
programmed to be updated by 2014. However, on being relegated, updating of the same was
ignored. The experts, in addition to streamlining and fast-tracking the recovery activity in the
DSICOs would also update the above document in three months for use in the �ields (DISCOs).
The release of the updated version of the RGTF Report would help the DISCOs to generate more
revenue, which can result in possibly lowering the consumer-end tariff
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Power Sector
APPENDIX F(a). REGULATORY FRAMEWORK: NEPRA
NEPRA Rules
• Licensing Distribution Rules, 1999

• Tariff Standards & Procedure Rules, 1998
• Fees Rules, 2002
• Fines Rules, 2002
• Licensing (Generation) Rules, 2000
• Performance Standards (Transmission) Rules, 2005
• Performance Standards (Distribution) Rules, 2005
• Performance Standards (Generation) Rules, 2009
• Uniform System of Accounts Rules, 2009
• Compalint Handling and Dispute Resolution (procedure) Rules, 2015
• Market Operator Registration Standards and Procedure Rules, 2015
NEPRA Regulations
• Competitive Bidding Tariff (Approval Procedure) Regulations, 2017

• Import of Electric Power Regulations, 2017
• Wheeling of Electric Power Regulations, 2016
• Distributed Generation and Net Metering Regulations, 2015
• Interconnection for Renewable Generation Facilities Regulations, 2015
• Supply of Electric Power Regulations, 2015
• Upfront Tariff (Approval & Procedure) Regulations, 2011
• Review Procedure Regulations, 2009
• Interim Power Procurement (Procedure & Standards) Regulations, 2005
• Resolution of Disputes between Independent Power Producers and other
Licensees Regulations, 2003
• Fees Pertaining to Tariff Standards & Procedure Regulations, 2002
• Licensing Application & Modi�ication procedure regulations, 1999
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Power Sector
Guidelines/ Codes
• Guidelines to Lay Down the Methodology & Process for Determination of Revenue
• Requirement and UOSC for Transmission Licensee
• Selection of Engineering, Procurement and Construction Contractor by
Independent Power
• Producers) Guidelines, 2017
• Sale of Electric Power by Renewable Energy Companies, Guidelines, 2015
• SOPs for Examination & Provision of Copies of Documents, 2015
• Guidelines for Determination of Consumer End Tariff Methodology and Process,
2015
• Commercial Code 2015 of CPPA-G
• Consumer Service Manual, 2010
• Grid Code, 2005
• Distribution Code, 2005
• Eligibility Criteria for consumers of distribution companies, 2003
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Power Sector
APPENDIX F(b). TARIFF DETERMINATION PROCEDURE
NEPRA receives a tariff petition from the company with their costs and revenue requirements
Registrar ascertains whether petition is �iled according to NEPRA rules
If satis�ied, he submits it to the Authority for formal admission within 14 days
Authority decides whether to admit the petition for consideration
If admitted, a case of�icer (CO) is assigned
Authority considers CO’s report and decides on the recommendations of the CO
CO holds meetings with petitioner, and submits report to the Authority within six months period
Public Hearing conducted.; NEPRA invites public to comments on the submissions of companies
CO prepare a draft determination based on Authority's instruction
Draft determination vetted by legal advisors. Signed by Authority and issued
Power Dividion noti�ies the tariff in the of�icial gazette
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Power Sector
APPENDIX F(c). ELECTRICITY TARIFF IN PAKISTAN: HISTORICAL PERSPECTIVE
Consumer-end Tariff Methodology
From 1960 to 1973: DBT, i.e., high rates for initial units and lower on succeeding
units. In the 1960s, 60 % of the electricity was produced from hydro sources;
therefore, initial units were expensive to cover the capacity price.
The trend reversed in 1973 to IBT, i.e., initial units became cheaper. Shortage of
energy capacity led to this change
Electricity tariffs for WAPDA have remained above the cost of production, that is,
above MC until 1996
Tariff for Distribution Companies
During the transition phase towards the complete corporatisation of the former
WAPDA companies, the bulk tariffs charged for the electricity purchased by the
distribution companies have been determined at the discretion of NTDC.
Until 2000, a uniform bulk tariff was charged to all distribution companies to
purchase electricity
In 2001, a new pricing methodology was established, allowing each distribution

company to retain a margin that re�lects its cash expenses, debt services, and line
losses (but not capital expenditures or non-cash expenses).
Source: Malik (2022) & Suhail (2014)
170

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POWER SECTOR

An Enigma with No Easy Solution

Research for Social Transformation & Advancement

Published by Research for Social Transformation & Advancement (RASTA),

Tel. +92 (51) 9248144, 9248137

All rights reserved: No part of this publication may be reproduced, stored in a

Book reviewed by Mr Anwar Kamal (Senior Advocate, Supreme Court of Pakistan,

Table of contents ....................................................................................................................i

1. POWER SECTOR: PREMIER CHALLENGES ............................................................3

1.1. Financial Viability and Power Sector Losses .................................................3

2. DISTRIBUTION CHALLENGES: WHY ARE DISCOS NOT DELIVERING?..........29

2.1. DISCO’s Major Challenges .................................................................................30

3. EXTERNALITIES AFFECTING ELECTRICITY DISTRIBUTION .........................47

3.1. Variation Across Distribution Companies ....................................................47

4. PRIVATIZATION OF DISTRIBUTION COMPANIES_ A FUTILE EXERCISE? .....51

4.1. Privatization of Electricity Distribution in Pakistan: History ................52

5. GENERATION BLUES ...........................................................................................58

5.1. Introduction .........................................................................................................58

6. IPPS THAT CHANGED THE POWER ARCHITECTURE IN PAKISTAN ............64

6.1. Beginning of IPPs Era in Pakistan .................................................................65

7. POWER CONTROL AND ALLIED ISSUES ...........................................................75

7.1. Load Dispatch Center (LDC): History ...........................................................75

8. ASSET MANAGEMENT AND PROCUREMENT IN POWER SECTOR ................88

8.1. Power Sector Procurement Process and Challenges ...............................88

9. POWER PLANNING: FAILURES OF THE LAST THREE DECADES ..................95

9.1. Introduction ........................................................................................................95

10. REGULATORY AFFAIRS AND CONSUMER-END TARIFF DESIGN ................104

10.1. Establishment of NEPRA ...................................................................................104

11. COMPETITIVE TRADING BILATERAL CONTRACT MARKET (CTBCM) .....123

11.1. Preface ..................................................................................................................123

12. FUTURE ARCHITECTURE OF THE POWER SECTOR .....................................131

12.1. Managerial Reforms .........................................................................................131

Figure 1.1. Circular Debt Growth (Rs Billion) ……………………………......................3

Table 1.1. Total Government Guarantees Stock_ Power Sector ……………………….4

ADB Asian Development Bank

Policymakers are taking decisions randomly or on the advice of international �inancial

PIDE POWER COMMISSION

▪ Engr TAHIR BASHARAT CHEEMA (Former MD, PEPCO) – Team Lead

▪ Dr NADEEM UL HAQUE (Vice Chancellor, PIDE)

The main recommendations include:

▪ Forensic audit of both public and private generation companies immediately,

Power Control & Allied Issues

▪ Comprehensive grid studies for steady-state and transient stability and

Asset Management and Procurement in Power Sector

▪ Ensure proper coordination between the functional departments

Power System Planning

▪ Fragmentation in power planning must change and go over to the Planning

Regulation & Consumer-end Tariffs

▪ NEPRA must be empowered to play its role as speci�ied in Clause 31 of the

Electricity Market: CTBCM

PAKISTAN POWER SECTOR (JUNE 30, 2021)

Circular Debt Rs 2.25 trillion (June 30, 2022)

Receivable Rs 1.68 trillion

Central Dispatch Transmission

PREMIER POWER SECTOR CHALLENGES

1. POWER SECTOR: PREMIER CHALLENGES

1.1. FINANCIAL VIABILITY AND POWER SECTOR LOSSES

Figure 1.1. Circular Debt Growth (Rs Billion)

Gross payable Amount swapped (PHPL)