B-3 industrial consumers: APTMA seeks enhancement of load limit

ISLAMABAD: The All Pakistan Textile Mills Association (APTMA) has sought enhancement of the existing load limit for electricity supply through 11 kV dedicated feeders from 7.5 MW to 10 MW for B-3 industrial consumers, subject to availability of grid and feeder capacity and recovery of proportionate grid-sharing charges under the National Electric Power Regulatory Authority (Nepra) Consumer Service Manual (CSM).

In a letter addressed to Chairman Nepra, APTMA said that at present, industrial consumers whose sanctioned load exceeds 7.5 MW are required to construct their own dedicated grid station and associated transmission infrastructure, even where sufficient capacity exists in the Disco’s grid and 11 kV feeder. This results in substantial non-productive capital expenditure, space constraints, and right-of-way challenges, without commensurate benefits.

In view of advancements in conductor technology, ensuing improved feeder capacity of the DDS/11 KV feeders, and the existing regulatory mechanism for proportionate grid-sharing charges, APTMA proposed that the current 7.5 MW ceiling be enhanced to 10 MW, subject to availability of grid and feeder capacity and full recovery of proportionate infrastructure costs.

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Existing Regulatory Position Clause 2.6.6 (Industrial) of the “Consumer Service Manual (Revised 2025)” (enclosed), titled “Requirement of Dedicated Transformer / Feeder / Grid Station”, provides that industrial consumers may be allowed: “…extension of load above 5 MW to 7.5 MW or a new connection up to 7.5 MW from the Disco’s owned grid station subject to availability of load in the grid and capacity in the 11 kV existing dedicated feeder.

In such a case the consumer will bear 100 percent grid sharing charges including transmission line charges and 100 percent cost of land proportionate to load above 5 MW to 7.5 MW.” Beyond 7.5 MW, the framework effectively requires installation of a dedicated grid station and associated transmission line, which in practice implies construction of a 132 kV grid and associated right-of-way infrastructure.

While the intent of the provision is understood and appreciated, its continued application at the current threshold creates material operational and economic inefficiencies for industry, the letter continued.

Practical Implications of the 7.5 MW Ceiling Industrial consumers whose load marginally exceeds 7.5 MW are presently required to construct a dedicated grid station (typically 132/11 kV) and arrange for a dedicated transmission line with associated right-of-way. This leads to several structural challenges.

According to APTMA, a typical 10 MW grid station costs approximately Rs 500–600 million. For medium-to large industrial units, this represents a substantial non-productive capital allocation. Such investment does not enhance productive capacity, export potential, or employment generation.

The same capital could otherwise be deployed in capacity expansion, technology upgradation, energy efficiency measures, or working capital support. From a national economic standpoint, this constitutes avoidable capital locking, APTMA argued.

Land and space constraints many industrial facilities, particularly in established clusters, as there is insufficient space to construct an in-house grid station meeting safety and clearance requirements. Retrofitting land for grid construction in urban or semi-urban industrial estates is often not technically or financially feasible.

Right-of-Way (RoW) constraints for 132 kV Lines Even where an industrial consumer is willing to construct its own grid station, obtaining RoW for a 132 kV transmission line presents serious legal and administrative hurdles. RoW approvals involve multiple provincial and local authorities, environmental clearances, crossing permissions (roads, canals, railways), and protracted negotiations with landowners. In many cases, these processes delay projects for years or render them infeasible.

The historical rationale for limiting 11 kV feeder loads was primarily related to distribution loss management, and technical constraints of conductor capacity and thermal limits. At the time such provisions were framed, standard conductors imposed meaningful limits on economically deliverable load at 11 kV.

However, with the deployment of modern HTLS (High Tension Low Sag) conductors and improved feeder designs, it is now technically feasible to transmit substantially higher MW levels over 11 kV feeders with lower resistive losses, improved thermal performance, and enhanced mechanical reliability. Therefore, the technical assumptions underpinning the 7.5 MW ceiling require re-examination of the Regulatory Precedent within the CSM.

CSM already permits extension of load from above 5 MW up to 7.5 MW and supply from Disco’s owned grid station via the existing 11 kV dedicated feeder, subject to availability of grid capacity, and payment of 100 percent grid sharing charges proportionate to incremental load.

This demonstrates that the regulatory framework already recognizes that subject to capacity availability and full cost recovery, higher loads may be accommodated without mandatory construction of a separate grid station. The same principle may now be logically extended from 7.5 MW to 10 MW.

APTMA further stated that the upper limit for supply through Disco’s owned grid station and 11 kV dedicated feeder under Clause 2.6.6 (Industrial) of the NEPRA Consumer Service Manual (CSM) be enhanced from 7.5 MW to 10 MW, subject to: (i) availability of load capacity in the grid station;(ii) availability of capacity in the 11 kV feeder, or upgradation through necessary re-conductoring; (iii) recovery of 100 percent grid sharing charges proportionate to incremental load; and (iv) technical feasibility certified by the concerned Disco.

This would maintain the cost-recovery principle already embedded in the CSM while removing unnecessary capital and administrative barriers for industrial consumers.

Copyright Business Recorder, 2026