The National Policy for Power Co-Generation by Sugar Industry (the Co-Gen Policy), notified in January 2008, aims to harness the potential of Pakistan’s sugar industry to contribute to the national power grid. This policy, developed by the Ministry of Water and Power and facilitated by the Private Power and Infrastructure Board (PPIB), is designed to promote environmental sustainability and cost-effective power generation through co-generation technology.

Vision and Objectives

The Co-Gen Policy seeks to leverage the sugar industry’s ability to produce electricity using bagasse, a fibrous residue from sugarcane. The main objectives of the policy are:

  1. Enhancing Power Generation Capacity: Utilizing the sugar industry’s potential to add over 3,000 MW to the national grid.
  2. Promoting Environmental Sustainability: Reducing greenhouse gas emissions by using bagasse, which has a higher calorific value and is environmentally friendly.
  3. Attracting Investment: Creating a simple and attractive framework for investors to develop co-generation projects quickly and efficiently.

Key Features of the Policy

1. Levelized Tariff

The policy offers a levelized tariff for 30 years, applicable to projects with a capacity of 60 MW or above, based on 28% net thermal efficiency. This tariff is designed to ensure financial viability and attract investment.

2. Fast-Track Development

Co-generation projects are to be developed on a fast-track basis, bypassing the need for pre-qualification, feasibility studies, and Letters of Interest (LOI). The PPIB issues Letters of Support (LOS) after the National Electric Power Regulatory Authority (NEPRA) determines the tariff within 45 days of receiving the feasibility report from the Pakistan Sugar Mills Association (PSMA).

3. Standardized Agreements

Existing Standardized Power Purchase Agreements (PPA) and Implementation Agreements (IA) are modified to cater specifically to co-generation projects. These agreements outline the responsibilities and rights of both the power producers and purchasers.

4. Fuel Flexibility

The policy allows for the interchangeability of bagasse and coal (imported or local) as fuel sources. This flexibility ensures that co-generation plants can operate beyond the sugarcane crushing season (November to February), using coal from March to October, thereby enabling year-round power production.

5. Incentives and Exemptions

Co-generation units benefit from the same incentives available to Independent Power Producers (IPPs) under the Policy for Power Generation Projects 2002. These include:

  • Customs duty exemptions on imported plant and equipment not manufactured locally.
  • Exemptions from income tax, turnover tax, and withholding tax on imports.
  • Free repatriation of equity along with dividends.
  • Permission for local and foreign financing.

6. Implementation Responsibility

Sugar mills are responsible for arranging financing, land acquisition, and procurement of machinery. They must set up the plants within 36 months of receiving the LOS, ensuring swift project execution.

Potential and Impact

Pakistan, being the fifth-largest sugarcane producer globally, has significant potential for electricity generation through co-generation. The policy estimates that utilizing bagasse from 83 sugar mills can generate over 3,000 MW of electricity, contributing significantly to the national grid and reducing the country’s reliance on expensive thermal power.

Environmental and Economic Benefits

The use of bagasse in power generation helps offset greenhouse gas emissions and provides a cleaner energy source. Economically, it offers a cost-effective solution to the country’s power shortages, reduces the need for fuel imports, and promotes local industry development.

Challenges and Considerations

While the policy is well-structured, several challenges need addressing for its successful implementation:

  1. Financing and Investment: Securing financing remains a challenge, especially in the face of political and economic instability.
  2. Regulatory Bottlenecks: Despite the fast-track provisions, bureaucratic delays can still pose significant hurdles.
  3. Technical Expertise: Developing and maintaining co-generation plants requires technical expertise, which may necessitate training and capacity-building initiatives.

Critical Analysis of Pakistan’s National Policy for Power Co-Generation by Sugar Industry 2008 from an International Perspective

While the National Policy for Power Co-Generation by Sugar Industry 2008 is an innovative approach to utilizing agricultural by-products for electricity generation, several aspects warrant critical examination from an international perspective. These concerns highlight the policy’s potential limitations and areas for improvement to align with global best practices.

1. Overreliance on Coal

The policy’s provision for using coal as a secondary fuel during the non-crushing season raises significant environmental concerns. Internationally, there is a strong move away from coal due to its high carbon emissions and environmental impact. Many countries are increasingly investing in cleaner alternatives such as solar, wind, and advanced biomass technologies. Pakistan’s reliance on coal for co-generation could lead to higher greenhouse gas emissions and undermine the environmental benefits of using bagasse. Additionally, this reliance might expose Pakistan to future international environmental regulations and carbon pricing, making these projects less viable.

2. Lack of Comprehensive Renewable Energy Integration

While the policy effectively leverages bagasse, it does not provide a broader framework for integrating other renewable energy sources. International best practices emphasize the importance of a diversified renewable energy mix to enhance energy security, reduce costs, and promote sustainability. Countries like Germany and Denmark have successfully implemented policies that support a variety of renewable energy sources, thereby ensuring a stable and resilient energy system. Pakistan’s policy could benefit from a more holistic approach that includes solar, wind, and other biomass resources.

3. Insufficient Emphasis on Technological Innovation

The policy does not strongly emphasize the adoption of cutting-edge technologies for co-generation. Internationally, the most successful co-generation projects employ advanced technologies that maximize efficiency and minimize emissions. Encouraging the adoption of high-efficiency co-generation technologies and providing incentives for technological innovation could significantly enhance the policy’s effectiveness. This includes exploring state-of-the-art bagasse processing technologies and integrating digital solutions for better plant management and efficiency.

4. Implementation and Regulatory Challenges

Despite the policy’s intent to streamline processes and fast-track development, bureaucratic inefficiencies and regulatory hurdles remain significant challenges. International investors often face delays and complications in navigating Pakistan’s regulatory landscape. Effective implementation of co-generation projects requires clear, transparent, and efficient regulatory processes. Countries with successful renewable energy policies, such as the United States and the United Kingdom, have established robust regulatory frameworks that facilitate swift project approval and execution. Pakistan needs to further simplify its regulatory procedures and enhance inter-agency coordination to attract and retain international investment.

5. Financial Viability and Investment Security

The policy provides various incentives and exemptions to attract investment; however, the financial viability of these projects can still be a concern. The global investment climate for renewable energy is highly competitive, and investors seek stable and predictable returns. Issues such as currency fluctuations, political instability, and economic uncertainty can deter foreign investment. Pakistan needs to offer more comprehensive financial instruments, such as long-term power purchase agreements (PPAs) and guarantees against political and economic risks, to secure international investment.

6. Environmental and Social Impact

The policy mandates compliance with environmental regulations, but it lacks detailed mechanisms for ensuring comprehensive environmental and social impact assessments (ESIAs). International standards, such as those set by the International Finance Corporation (IFC) and the Equator Principles, emphasize rigorous ESIAs for all large-scale projects. Ensuring that co-generation projects adhere to these standards is crucial for mitigating negative impacts on local communities and the environment. Pakistan must adopt and enforce robust ESIA processes to gain local and international support for its co-generation initiatives.

7. Long-Term Sustainability and Policy Continuity

While the policy is forward-looking, its long-term sustainability depends on consistent government support and policy continuity. International experience shows that abrupt changes in policy direction or support mechanisms can destabilize the renewable energy sector. To ensure the long-term success of the co-generation policy, Pakistan must commit to sustained support and create a stable policy environment that withstands political and economic fluctuations.


The National Policy for Power Co-Generation by Sugar Industry 2008 represents a significant step towards leveraging Pakistan’s agricultural resources for power generation. However, from an international perspective, several critical challenges need to be addressed to enhance its effectiveness and sustainability. These include reducing reliance on coal, integrating a broader range of renewable energy sources, promoting technological innovation, streamlining regulatory processes, ensuring financial viability, adhering to international environmental standards, and maintaining policy continuity. By learning from global best practices and addressing these issues proactively, Pakistan can optimize its co-generation potential and contribute more effectively to its energy security and environmental goals.

By The Josh and Mak Team

Josh and Mak International is a distinguished law firm with a rich legacy that sets us apart in the legal profession. With years of experience and expertise, we have earned a reputation as a trusted and reputable name in the field. Our firm is built on the pillars of professionalism, integrity, and an unwavering commitment to providing excellent legal services. We have a profound understanding of the law and its complexities, enabling us to deliver tailored legal solutions to meet the unique needs of each client. As a virtual law firm, we offer affordable, high-quality legal advice delivered with the same dedication and work ethic as traditional firms. Choose Josh and Mak International as your legal partner and gain an unfair strategic advantage over your competitors.

error: Content is Copyright protected !!