LAHORE: The Federation of Pakistan Chambers of Commerce and Industry (FPCCI) has objected to the Indicative Generation Capacity Expansion Plan (IGCEP) 2025-35, submitting its observations to the National Electric Power Regulatory Authority (Nepra) following a public hearing on May 20.
In a letter through its Energy Advisory Committee, the FPCCI said the PLEXOS costing methodology underpinning IGCEP 2025-35 was fundamentally flawed. It cited incorrect assumptions, a pre-committed project bias with cost optimisation disabled, and incomplete costing that excluded $10.6 billion in Transmission System Expansion Plan 2025-35 (TSEP) costs.
PLEXOS is a software used globally by power companies, grid operators, and policymakers to model, forecast, and optimise complex energy system.
The federation argued that “least cost” did not mean “affordable”, noting that no assessment had been made of whether Rs49 per unit — the cheapest option in the model — was affordable for consumers. It urged Nepra to impose affordability as a binding constraint.
Says IGCEP 2025-35 is flawed over costing errors, unaffordable tariffs
It added that after committing more than $57 billion to generation and transmission, the IGCEP did not guarantee that consumer tariffs would remain at or below the current 12 cents per kWh, or Rs33.38/kWh. If it could not, the plan failed its stated purpose, the FPCCI said.
The federation also said the Water and Power Development Authority (Wapda) projects were structured as 100pc pass-through obligations with no cap on cost overruns. It cited the Neelum-Jhelum precedent and Wapda’s current tariff petition before Nepra as evidence that consumers ultimately bore every rupee of overrun, calling the model unsustainable for new commitments of over $10.5bn.
It recommended that all committed public-sector projects — Diamer Bhasha, Dasu, Mohmand, Tarbela Extension-5, CASA-1000 and C-5 nuclear — be declared “strategic” under the National Electricity Policy 2021 and funded through the Public Sector Development Plan (PSDP) and federal budget, not consumer bills.
The FPCCI said the industrial demand ‘growth’ cited in the IGCEP reflected fuel switching rather than new economic activity. Its own monthly data showed total industrial energy use, including grid and captive gas, fell 9pc even as grid consumption rose. The GDP-to-electricity correlation model was broken and invalid as a planning basis, it said.
The federation urged Nepra to reject the plan and return it for resubmission using correct demand projections, year-wise rupee tariff forecasts for all scenarios, a binding cap on capacity purchase price at 25pc of the consumer end tariff, and funding of strategic projects through the PSDP.
Published in Dawn, May 24th, 2026
