The recent article “Net-Metering Saga: Much Ado About the 0.83 Percent” by Ammar H. Khan, published in Dawn on March 24, 2025, attempts to justify a tariff of Rs. 10/unit for solar exported units. Mr. Ammar presents a narrow, academic examination of the marginal pricing of electricity generated during peak sunlight hours. However, one must question whether this single point (though it is not valid) justifies the abrupt reduction in tariffs for solar electricity exports. The very fundamental basis of “marginal hourly pricing” is incorrect, as it is not in practice in Pakistan.
Moreover, it is essential to analyze what impact this policy will have on achieving the government’s Alternative Renewable Energy (ARE) Policy 2019 objectives. To me, this revision contravene the objectives outlined in the ARE Policy, which was approved by the Council of Common Interests on October 2, 2020. Can an abrupt administrative decision, made on the basis of incomplete and ill-advised reasoning, override the decision of the powerful Council of Common Interests (CCI)?
According to the second paragraph of the Foreword of the ARE Policy 2019, the strategic objectives include: (i) energy security, (ii) affordability of electricity, (iii) availability for all, (iv) environmental protection, (v) sustainable development, (vi) social equity, and (vii) mitigation of climate change. It also states that the ARE Policy 2019 aims to create a conducive environment for the sustainable growth of the ARE sector in Pakistan. A holistic, multi-disciplinary (inter alia from finance, legal, commercial, and technical and regulatory aspects) review of the policy, rather than isolated academic analysis, is needed, taking into account the country’s real-world conditions and minimizing disruptions to consumers and the public. 
The ARE Policy 2019 was designed to achieve several strategic goals, including energy security, affordability, availability, environmental protection, sustainable development, social equity, and climate change mitigation. It emphasized the creation of a conducive environment for the sustainable growth of the renewable energy sector. A holistic review of the policy, rather than isolated academic analysis, is needed, taking into account the country’s real-world conditions and minimizing disruptions to consumers and the public.
The academic thesis by Mr. Ammar has little relevance to the reality on the ground. The “Duck Curve,” which looks attractive as a picture, is not applicable in Pakistan. As is widely known our curriculum is far behind the industrial and technological developments on the ground. The reference to marginal pricing across the world by Mr. Ammar seriously lacks knowledge of the realities on the ground, as we cannot assume any close comparisons of operations, efficiency, T&D losses, and transparency of the utilities across the world with the current state of Pakistan’s power sector. Consumers’ electricity bills are not based on hourly changes in the marginal tariff. As a layman, I know that there are only two time-of-use slabs for tariff, peak unit rate and off-peak unit rate. The solar-generated and exported units are generally during off-peak hours, so they should be set off at the same off-peak hours units or rate. The peak hours’ use of grid electricity is charged at the peak rate anyway. That would satisfy the requirement of “social equity” as is enshrined in the ARE policy 2019.
Mr. Ammar also suggested that net-metering users seeking complete independence could invest in battery storage to avoid reliance on the grid. At least it is acknowledged that a reduction in solar export tariff will cause additional costs to society in the shape of battery storage, and also the cost of labour and hybrid inverters, if I may add. 
As a litmus test, any change in policy which results in unquantifiable additional costs to society cannot be termed as an appropriate change. In public projects, the basic consideration is always that the benefits should outweigh the costs to society as a whole, rather than focusing on the impact to any specific segment. Without such fundamental considerations, any decision, order, or policy change is often driven by vested interests and bureaucratic red tape.
Knowingly enough Mr. Ammar further believes that battery costs of storage batteries may be around 50% of what they are today by the year 2030. Upon deeper reflection, one of the immediate externalities caused by this decision would result in additional unnecessary costs to society, further reducing the demand for electricity from the grid and causing more operational risks to the grid. Reduction in the cost of batteries is bound to mass adoption. This trend will continue to increase strain on the grid, as the reduction in demand for electricity will further push tariffs up as average capacity charges continue to rise for those who remain connected to the grid.
Mr. Ammar claims that over 70% of such users are in high-income areas of Karachi, Lahore, Rawalpindi, and Islamabad. This effectively becomes a problem of the rich, who can make the most noise, relative to the other 99.1% of households in the country. While I may agree with this statement, I would also argue that this high-income segment of society is also the tax-paying segment. The tax collected from them is spent on the low-income segment in the form of solar panels and other subsidies. Having said that, if the current or emerging issue is operational challenges of the grid, such issues will continue to increase with the increasing number of solar systems distributed to the masses out of taxpayers money mainly contributed by the high-income segment of society.
At this juncture, it is appropriate to remind ourselves that on one hand, the Punjab and Sindh governments are providing free solar systems, and on the other, solar consumers are being discouraged by reducing the purchase price of net-exported units based on whimsical justifications. This situation presents a policy paradox where the Punjab and Sindh governments are promoting solar adoption through free solar systems for low-income households, while the federal government and power regulators are discouraging solar exports by reducing the purchase price of net-exported electricity. This dual approach has contradictory economic implications for Pakistan’s power sector and is clearly creating more social disorder, uncertainty, a negative investment climate and a counterproductive focus on the too petty matters.
All those poor who qualify to get the solar system should be kept connected to the grid and supplied electricity without being charged taxes on the electricity. There will be no loss to the government, as they will not pay any taxes on the solar electricity generated and used off-grid through free solar systems. This aspect must be deeply studied, analyzed, and simulated before reaching any conclusive decision based on a short-sighted view and reactive approach without a thorough analysis of the potential outcome. Wish that Mr Ammar had also at least quantified the fiscal incentives provided by other countries in the world to the solar users in the shape of interest-free investment, net meter tariffs, and other incentives.
Interestingly, Mr. Nadeem Javaid, in his article “Beyond the Red Tape,” published in The News International on March 24, 2025, argues that Pakistan’s bureaucracy, characterized as a “machine bureaucracy,” is rigid and rule-bound, prioritizing procedural correctness over actual outcomes. This structure maintains the status quo through layers of approvals and outdated protocols, discouraging reform and innovation. Such an environment fosters red tape, corruption, and unpredictability, eroding public trust and hindering economic potential.
Mr. Nadeem emphasizes that while rules are essential for maintaining order, excessive formalization and contrived ambiguity in policies allow bureaucrats to exercise discretionary power, making processes unnecessarily complex. This complexity deters investment and hampers economic growth, as seen in Pakistan’s convoluted taxation system, which serves as a tool for bureaucratic control rather than efficient revenue collection.
If the issue is merely operational challenges of the grid, the “experts” like Syed Faizan Ali should focus on resolving the operational issues rather than resolving operational matters through tariffs. Why can’t our expert review the possibility of adjusting the dispatch parameters of power plants which are on a “take and pay” basis and on fossil fuels? If during peak solar power generation hours, the dispatch of such IPPs could be restricted to optimize solar power generation, it will have a positive impact on the environment, foreign exchange, energy security, affordability of electricity, availability for all, environmental protection, sustainable development, social equity, and climate change mitigation, which are the prime objectives of the ARE Policy 2019.
In general, our bureaucratic approach is to pass the buck on to others rather than putting their own house in order. Instead of addressing systemic weaknesses and focusing on available solutions directly under their administrative controls, bureaucrats often introduce further complexities, exacerbating existing challenges.
Temporary and makeshift bureaucratic decisions can do more harm than good, often causing long-term damage to the economy, social fabric, and the environment. While they may offer short-term relief, these decisions rarely address the root causes of issues and frequently lead to unintended consequences. For instance, hastily implemented policies—whether in energy, governance, or other sectors—can disrupt existing systems, create inefficiencies, and erode public trust. Over time, they can deepen social inequality, harm the environment, and destabilize the economy and social fabric.
So far, there has been no concrete plan or even substantive observations from the Syed Faizan Ali, being member of the PM’s Solarization committee, regarding measures to curb theft, losses, inefficiencies, corruption, maladministration, and misappropriation within the electricity distribution, generation, regulatory, and governance systems relating to the areas under his able advisorship. Instead, the focus remains on extracting easy revenue from consumers who are already overburdened with more than a dozen taxes and subjected to the highest electricity tariffs in the region.
The saying, “He who knows not that he knows not is a fool, shun him,” points to the dangers of ignorance in leadership. Leaders or decision-makers who are unaware of their own knowledge gaps can make uninformed choices that have negative consequences. This highlights the importance of self-awareness, continuous learning, and consulting with experts when making decisions. Thoughtful and well-informed planning is essential to ensuring that decisions lead to sustainable, positive outcomes.
Until a multidisciplinary team of competent professionals is engaged for the periodic policy review, with the assistance of advanced ‘technology governance’ tools, the outcome is bound to have more adverse externalities than bringing any sustainable good.
Muhammad Arif; Principle Oil and Gas Lawyer @ Arif and Associates and President of Consumer Rights Advocacy. He can be reached at [email protected] and [email protected] | 0333 5191381.
(This article reflects author’s opinion and not necessarily the views of WNAM )
