NEPRA has approved an 11-year power generation and transmission expansion plan involving around $58 billion in investment through 2035, despite significant reservations recorded by all three members of the regulator. The approval covers the Integrated System Plan 2025 and was issued through a 45-page decision, with implementation subject to the concerns and observations raised by the authority being addressed.
The decision includes more than 12 pages of dissenting or separate advisory notes from NEPRA members. The regulator questioned the inclusion and exclusion of several major projects and also raised concerns about the plan’s constitutional standing, particularly over its apparent bypassing of the Council of Common Interests, which serves as the constitutional forum for matters involving national energy policy and planning.
The plan uses a low-growth business-as-usual scenario as the reference case for future generation requirements. It assumes average annual gross domestic product growth of 3.52 percent and provides for 26,045 megawatts of additional generation capacity. Of this, 17,485 megawatts consists of capacity that has already been committed, while another 8,560 megawatts has been identified through optimisation.
After accounting for the retirement of 2,577 megawatts of existing generation capacity, Pakistan’s total installed generation capacity is projected to reach 62,657 megawatts by 2035. The plan also incorporates 8,120 megawatts of net metering capacity. The estimated investment required for the additional generation capacity has been placed at $47.08 billion, making generation the largest component of the overall expansion programme.
Transmission infrastructure represents another major portion of the investment. NEPRA estimates that around $10.65 billion will be required for transmission projects during the planning period. This includes approximately $4.6 billion for ongoing or already committed projects and another $6.05 billion for new transmission expansion. The planned infrastructure covers power evacuation schemes, network reinforcement, additional extra-high-voltage substations, transformer expansion and facilities designed to support voltage control.
The plan also proposes a 40-megawatt on-site power plant for the Gwadar and Makran region. The facility is intended to address electricity supply concerns in the area following disruptions to electricity imports from Iran. The proposal forms part of the broader transmission and generation planning framework aimed at improving supply reliability in regions facing specific grid constraints.
NEPRA, however, rejected a proposed $900 million investment in battery energy storage systems at this stage. The regulator said a detailed technical and economic assessment should first establish the need for the storage systems, determine their appropriate capacity and operational requirements, and demonstrate their cost effectiveness before such investment is incorporated into the expansion plan.
Another major concern involved conflicting positions from the Independent System and Market Operator and the Power Planning and Monitoring Company regarding the effect of the proposed expansion on consumer electricity tariffs. NEPRA directed that the impact on consumer-end tariffs should be properly calculated and incorporated into the main plan so that the financial consequences of the proposed investments can be assessed more clearly.
According to projections from the Power Planning and Monitoring Company, the consumer-end base electricity tariff could reach Rs37.28 per unit by 2035, compared with Rs34 per unit during 2024-25. The projected increase adds further importance to NEPRA’s demand for a clearer assessment of how generation and transmission investments will affect electricity consumers over the coming decade.
NEPRA also criticised the Independent System and Market Operator for disclaiming responsibility for the accuracy, authenticity and completeness of the data and projections used to prepare the Integrated System Plan. The regulator said these concerns need to be addressed before the plan can move toward full implementation, highlighting the importance of reliable data and transparent assumptions in determining Pakistan’s long-term electricity investment requirements.
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