Power Generation, Transmission and Distribution 2025

PAKISTAN Law and Practice Contributed by: Nadir Altaf and Muhammad Fahim Khan, RIAA Barker Gillette

cial governments, will notify a national electric- ity plan every five years. In pursuance of this requirement, the federal government has noti- fied the National Electricity Plan 2023–27 (“Plan 2023”). Plan 2023 has indicated certain reforms in the power sector, which include: • issuance of a new generation policy and updates to the existing transmission policy; • facilitative policies and regulations to be approved for the application of hydrogen and battery storage technology in the power sec- tor; • the transfer of ownership of federally owned DISCOS to the provinces; • discontinuation of upfront tariffs for genera- tion and transmission projects; and • inclusion of cross subsidy in open access charges. The foregoing is not exhaustive. New Alternative and Renewable Energy Policy 2019 The Alternative and Renewable Energy Policy 2019 (the “2019 ARE Policy”) places a greater emphasis than the previous renewable energy policy (namely, the Policy for Development of Renewable Energy for Power Generation 2006) on: • competitiveness, which is ensured through bidding; and • “new” technologies, which are encouraged through a framework for unsolicited proposals that removes the requirement for competi- tive bidding (this framework is available for the first two power projects using each new technology). The 2019 ARE Policy extends to projects that are based on:

• biomass (including bagasse, agricultural waste and other waste); • solar (photovoltaic or thermal, or any technol- ogy that uses heat and/or light from the sun to generate electricity); • wind; • storage technologies (battery systems, cells of all types, compressed gas, pumped stor- age); • biogas using any organic material (except fossil fuels); • energy from waste; and • hybrids of any of the above-mentioned tech- nologies. The foregoing is not an exhaustive list. Transmission Line Policy 2015 Recognising the need to augment the national transmission network, the federal government published the Transmission Line Policy 2015 (the “Transmission Policy”). So far, the Matiari- Lahore transmission line is the only project that has been developed under the Transmission Pol- icy (see 4.2 Obtaining Approvals to Construct and Operate Transmission Lines and Associ- Projects developed under older policies (eg, the 2015 Policy and the Policy for Power Genera- tion Projects Year 2002) continue to enjoy the concessions and protections granted to them under such policies. 1.8 Unique Aspects of the Power Industry High-Risk, High-Reward Market Pakistan is a challenging country to invest in – for reasons ranging from security risks and cir- cular debt to bureaucratic red tape. As a result, the government offers some of the highest ated Facilities for further details). Projects Under Older Policies

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