Proposed Loan of Balakot
Proposed Loan of Balakot
Proposed Loan of Balakot
Distribution of this document is restricted until it has been approved by the Board of Directors.
Following such approval, ADB will disclose the document to the public in accordance with ADB’s
Access to Information Policy.
CURRENCY EQUIVALENTS
(as of 16 January 2021)
ABBREVIATIONS
NOTES
(i) The fiscal year (FY) of the Government of Pakistan and its agencies ends on
30 June. “FY” before a calendar year denotes the year in which the fiscal year
ends, e.g., FY2021 ends on 30 June 2021.
In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area.
CONTENTS
Page
PROJECT AT A GLANCE
I. THE PROPOSAL 1
II. THE PROJECT 1
A. Rationale 1
B. Project Description 6
C. Value Added by ADB 7
D. Summary Cost Estimates and Financing Plan 7
E. Implementation Arrangements 9
III. DUE DILIGENCE 10
A. Technical 10
B. Economic and Financial Viability 11
C. Sustainability 11
D. Governance 12
E. Poverty, Social, and Gender 13
F. Safeguards 13
G. Summary of Risk Assessment and Risk Management Plan 15
IV. ASSURANCES 15
V. RECOMMENDATION 15
APPENDIXES
1. Design and Monitoring Framework 16
2. List of Linked Documents 19
Project Classification Information Status: Complete
PROJECT AT A GLANCE
Cofinancing
Adaptation ($ million) 2.61
Mitigation ($ million) 277.39
Sustainable Development Goals Gender Equity and Mainstreaming
SDG 5.c Effective gender mainstreaming (EGM)
SDG 7.1
SDG 13.a Poverty Targeting
General Intervention on Poverty
4. Risk Categorization: Complex
.
6. Financing
Modality and Sources Amount ($ million)
ADB 300.00
Sovereign Project (Regular Loan): Ordinary capital resources 300.00
Cofinancing 280.00
Asian Infrastructure Investment Bank - Project loan (Partial ADB 280.00
Administration)
Counterpart 175.00
Government 175.00
Total 755.00
1. I submit for your approval the following report and recommendation on a proposed loan to
the Islamic Republic of Pakistan for the Balakot Hydropower Development Project.1 The report
also describes the proposed administration of a loan to be provided by the Asian Infrastructure
Investment Bank (AIIB) for the Balakot Hydropower Development Project, and if the Board
approves the proposed loan, I, acting under the authority delegated to me by the Board, approve
the administration of the loan.
2. The project will finance the construction of a 300-megawatt (MW) run-of-river hydropower
plant on the Kunhar River in Mansehra District, Khyber Pakhtunkhwa Province. The project will
(i) improve energy security by increasing the clean energy share in the country’s energy mix,
which is dominated by thermal power generation; (ii) boost the economy and promote revenue-
generating investments in the hydro-abundant Khyber Pakhtunkhwa Province; and (iii) build
capacity and awareness on climate change impacts, adaptation, and mitigation measures.2 The
project also targets improving the quality of life of women in communities surrounding the project
area and promotes gender mainstreaming.
A. Rationale
3. Sector structure and energy mix. Since 2002, Pakistan has been unbundling and
restructuring its energy sector. The Water and Power Development Authority, the sole vertically
integrated entity previously controlling the entire sector, was unbundled into 10 regional
distribution companies, four government-owned thermal power generation companies
(GENCOs), a transmission company, and a centralized agency—the Central Power Purchasing
Agency Guarantee Limited (CPPA-G)—to purchase power from all GENCOs and independent
power producers (IPPs). Privately owned Karachi Electric Supply Company is responsible for
generating and distributing power in Karachi and is listed on the Pakistan Stock Exchange. Nearly
50% of the country’s total installed capacity is provided by private sectors led IPPs. Pakhtunkhwa
Energy Development Organization (PEDO), a fully state-owned entity, is responsible for investing,
developing, and operating hydropower plants in Khyber Pakhtunkhwa Province using public
sector financing, as well as acting as a one-window facilitator for private sector investors who
intend to invest in hydropower projects in the provincial territory and avail of the concessions
under the KP Hydropower Policy 2016.3 The National Electric Power Regulatory Authority
(NEPRA) was established to determine tariffs, issue licenses, and regulate and ensure the long-
term sustainability of the sector. All IPPs, state-owned, and province-owned electricity generation
units sell electricity to the CPPA-G, mostly based on take-or-pay power purchase agreements.
4. In FY2019−2020, the total installed capacity in country was about 39 gigawatts (GW)—an
energy mix dominated by thermal energy—with almost 60% generated from oil-, gas-, and coal-
fired power plants, 29% from hydropower and remaining 11% from other sources including solar,
1 Previously called the Hydropower Development Investment Project, the project’s name was revised after the funding
modality was changed from a multitranche financing facility to a stand-alone project. Asian Development Bank
(Central and West Asia Department). 2019. PAK: Hydropower Development Investment Program – Request for
Approval of Change in Financing Modality. Memorandum. 21 June (internal).
2 The Asian Development Bank (ADB) provided transaction technical assistance to develop the proposed Balakot
Hydropower Development Project. ADB. 2016. Technical Assistance to the Republic of Pakistan for Hydropower
Development Investment Program. Manila (TA 9185-PAK).
3 Government of Khyber Pakhtunkhwa. 2016. KP Hydropower Policy 2016. Peshawar.
2
wind, nuclear, and bagasse. Generation costs were substantially skewed toward oil- and gas fired
power plants, with 46% of the total cost in FY2017.4 The decade old demand-supply gap has
been curtailed by adding 13 GW of generation capacity (mostly gas-fired or coal-based) to the
national grid from 2016−2020 but with projected demand growth of 15 GW by 2030 and
decommission plan of 5 GW of inefficient thermal and diesel plants by 2025, more additions are
still required to meet future needs.
5. Sector issues. Key issues faced by Pakistan’s power sector include (i) recurring circular
debt, (ii) an unsustainable and unaffordable energy mix with heavy reliance on imported fuel-
based electricity generation, (iii) a stressed transmission and distribution network, and (iv) the
slow pace of reforms. The government made large investments in transmission, distribution, and
generation from 2009 to 2019, but system stability and reliability have not been fully resolved
mainly because of cash constraints caused by recurring circular debt and network bottlenecks
caused by old infrastructure and growing demand. While further planned investment in the
network will improve system reliability, sustainability and affordability cannot be achieved unless
the key issues that feed the circular debt—to which imported fuel-based generation and the slow
pace of reforms are major contributors—are resolved. This project will contribute to improving the
energy mix by increasing the clean energy share and reducing the reliance on imported fuel. A
thermal-dominant energy mix for a fuel-importing country with weak hedging systems not only
makes a country vulnerable to price fluctuations and abnormal tariff increases, but also burdens
its foreign reserves and exposes it to unnecessary foreign exchange risks.
6. Other factors contributing to circular debt are weak governance of sector institutions,
inadequate cost recovery consumer tariffs, and mismatched subsidies, which are being
addressed in parallel through a structured reform program prepared by the government with
support from development partners, including the Asian Development Bank (ADB). Through this
reform program, the sector will (i) secure financial sustainability by controlling accumulation and
addressing reduction of circular debt; (ii) strengthen governance by rationalizing a competitive
market road map, separating policy and regulatory functions in hydrocarbons, appointing
appellate tribunals, implementing multiyear tariffs, and unbundling the gas subsector; and (iii)
reinforce infrastructure improvements through integrated planning to facilitate public and private
sector investments across the energy supply chain.5
7. Balancing the energy mix has been a challenge for the government mainly because of
large investment needs and the focus on solutions that could be implemented in the shortest
possible time to address the large demand–supply gap affecting the country since 2007. To some
extent, this has been effective in reducing the demand–supply gap, but focusing on short-term
solutions increased reliance on imported fuel-based power plants, which in turn has made the
sector less sustainable and affordable. To resolve these issues, the share of clean energy has to
be substantially increased. Developing new hydropower plants can play an important role not only
by increasing the share of clean energy but also by generating large economic activities
associated with the construction of mega projects, such as hydropower plants. Pakistan is rich in
hydropower resources, but despite 100 GW of recognized and 60 GW of identified hydropower
potential (30 GW of which are in Khyber Pakhtunkhwa), only 9,861 MW (16%) have been
harnessed (5,729 MWs in KP), including 472 MW of hydropower added by private sector.
Pakistan added 2.5 GW of hydropower to its energy mix in 2018, but considering Pakistan’s huge
hydropower potential and need for clean energy, its energy mix should be further rationalized and
come from more hydropower and other renewable energy sources.
8. Recognizing the challenges, the government introduced the Power Generation Policy
2015 to (i) empower the provincial governments to function as facilitators for IPPs, (ii) simplify
investment decision-making by local and federal authorities, (iii) identify zones of responsibility in
processing and implementing generation projects, and (iv) extend the federal government’s
support of backing up the power purchaser payment obligation and political and other risks in the
projects to the provincial government-initiated projects when conforming to certain requirements.6
In parallel, the Government of Khyber Pakhtunkhwa issued the KP Hydropower Policy 2016
(footnote 3), which assigned PEDO as the single facilitator for all investors in hydropower projects
in the province and aims to develop projects through the private and public sector windows.
10. Rationalizing the generation mix aligns with ADB country partnership strategy, 2021−2025
outcomes, which prioritize developing domestic energy resources such as hydropower and
renewable energy; and promoting greater availability, affordability, and efficiency in the sector.
The project is included in ADB’s country operations business plan, 2020–2022 for Pakistan.7 It
supports (i) ADB Strategy 2030 operational priorities 1, 2, 3, 5, and 6 by helping reduce remaining
poverty and inequalities, accelerate progress in gender equality and reduce women’s time
poverty, tackle climate change, build climate and disaster resilience, enhance environmental
sustainability, promote rural development, and improve the financial management of PEDO; and
(ii) Sustainable Development Goals 5, 7 and 13 by providing affordable, clean, and sustainable
energy; and meeting Pakistan’s climate change mitigation and adaptation objectives.8
6 Government of Pakistan, Ministry of Water and Power. 2015. Power Generation Policy 2015. Karachi.
7 ADB. 2020. Country Partnership Strategy: Pakistan, 2021−2025. Manila; and ADB. 2019. Country Operations
Business Plan: Pakistan, 2020−2022. Manila.
8 ADB. 2018. Strategy 2030: Achieving a Prosperous, Inclusive, Resilient, and Sustainable Asia and the Pacific. Manila;
United Nations. Sustainable Development Goals. Goal 5: Gender Equality; United Nations. Sustainable Development
Goals. Goal 7: Affordable and Clean Energy; and United Nations. Sustainable Development Goals. Goal 13: Climate
Action.
4
11. Lessons and experiences. The Independent Evaluation Department reviewed ADB’s
energy investments in Pakistan since 2005 and made two recommendations based on
experiences and lessons from ongoing projects: (i) strategic—strengthen support for clean energy
and conservation by investing in renewable energy generation and energy efficiency; and review
the renewable energy policy and associated regulations to increase the share of renewable
energy in the mix, reduce generation costs, and mitigate climate change impacts; and
(ii) operational—promote sovereign investments to lower baseload power generation costs,
building on sound integrated energy planning to increase Pakistan’s energy security by reducing
its dependency on imported fuels.9 These recommendations have been incorporated in ADB
investment plans. ADB is supporting the first recommendation through the ongoing policy-based
program loan (footnote 5) and the second by focusing sovereign investments on hydropower
development, such as in this project. Such projects will lower generation costs and reduce the
sector’s reliance on imported fuel. The new Alternative and Renewable Energy Policy 2020
approved in July 2020 set a target to increase the renewable energy share from 3.40% in 2020 to
20% by 2025 and 30% by 2030 (footnote 4). In June 2020, the World Bank approved a $500
million multisector policy-based program-Resilient Institutions for Sustainable Economy (RISE).
The energy component of RISE supports Pakistan’s transition to low carbon energy and
development of indigenous resources for clean energy generation through deployment of
renewable energy and hydropower sources.
12. ADB has been engaged with PEDO since 2005 and has not only contributed to PEDO’s
investment needs but also provided extensive support in developing plans, strategies, capacity
building, improvements in institutional setup, and reforms. ADB supported developing PEDO’s
corporatization plan, which the PEDO board of directors approved for implementation. The plan
includes strengthening financial systems and creating special purpose vehicles to enhance
institutional efficiency and financial management. Among all development partners, ADB has the
longest and most valued relationship with PEDO. With ADB assistance of $44 million, PEDO has
developed two run-of-river hydropower plants with capacity of 20 MWs to generate 105 gigawatt-
hours of electricity annually.10 ADB has also provided $237 million to support the provincial
government’s initiative to provide 2.4 million people and 8,000 schools with reliable access to
electricity through innovative business models by engaging communities in developing and
operating micro hydel plants (hydropower plants with capacity less than 1,000 kWs).11 These
interventions and innovative business models will help Khyber Pakhtunkhwa increase access to
electricity by using clean energy resources and engaging communities.
9 Independent Evaluation Department. 2019. Sector Assistance Program Evaluation: ADB’s Support to Pakistan
Energy Sector, 2005–2017. Manila: ADB.
10 ADB. Pakistan: Renewable Energy Development Sector Investment Program—Project I.
11 ADB. 2016. Report and Recommendation of the President to the Board of Director: Proposed Results-Based Loan
and Technical Assistance Grant to the Islamic Republic of Pakistan for the Access to Clean Energy Investment
Program. Manila.
5
bilateral partners support the Government of Pakistan in enhancing hydropower capacity, with a
combined active portfolio of $372 million, including the construction of hydropower plants
(211 MW) and the rehabilitation of the 243 MW Warsak Hydropower Plant. The involvement of
major development partners in harnessing Pakistan’s hydropower potential has helped initiate
multiple projects, employing both stand-alone and cofinancing options, depending on country
partnership strategies and institutional priorities. Private sector participation in hydropower-based
generation is expected to increase, with 1,611 MW to be commissioned in 2021–2022 and
another 4,851 MW planned to be added to the system by 2030. Between 2021 and 2030, the
private sector will add about 12,478 MW of generation capacity dominated by 51.79% of
hydropower.
14. Economy and COVID-19 impact. Pakistan’s episodic pattern of economic growth is
characterized by periods of boom and bust. A narrow production and export base has made the
economy less resilient to economic shocks, restricted trade, and resulted in a binding balance-of-
payments constraint to growth. Domestic resource mobilization is severely limited. A large fiscal
deficit, weak external position, and eroded macroeconomic buffers reflect structural weaknesses
in economic management. Consequently, the fiscal and monetary policy adjustments needed to
correct these economic imbalances are limiting the fiscal space to tackle Pakistan’s infrastructure
deficit, raising the cost of doing business for the private sector, and holding back the country’s
international competitiveness. Governance bottlenecks and institutional capacity challenges
persist. Gross domestic product (GDP) growth contracted 0.4% in FY2020 as the coronavirus
disease (COVID-19) pandemic affected consumer demand and private sector activity, leading to
a sharp decline in economic activity. The current account deficit narrowed substantially from 4.8%
of GDP in FY2019 to 1.1% in FY2020, with exports and imports declining because of the
pandemic. Remittances maintained an upward trend, rising 6.4% in FY2020 despite some
monthly volatility from COVID-19 restrictions in the Middle East. The fiscal balance recovered
from a deficit of 9.1% of GDP in FY2019 to 8.1% in FY2020. The Pakistan rupee stabilized at
about PRs158 against the United States dollar in FY2020.
15. The COVID-19 pandemic also delayed advance procurement actions under the project.
The bidding period was extended multiple times to accommodate requests from international
bidders because of lockdowns in multiple countries. The project implementation design includes
instructions to contractors on preparing and implementing an effective COVID-19 health and
safety plan. In general, the project will positively contribute to boosting the indirect economic
impact in the province by generating jobs and construction activities. Once operational, the
province can use the revenues generated from the hydropower plant to improve health and
education facilities.
16. Climate change. Hydropower generation is at the nexus of Pakistan’s climate change
adaptation and mitigation priorities and objectives. Scaling up large hydropower generation,
building climate-resilient water-related infrastructure, and enhancing water resource management
are among the country’s priority climate actions.12 The country is among the most vulnerable to
climate change, with water resources and energy particularly at risk from expected increases in
the magnitude and frequency of extreme weather events such as floods, droughts, and high
temperatures.13 Under the Paris Climate Agreement, Pakistan has committed to reduce by 2030
12 Government of Pakistan. 2016. Pakistan’s Intended Nationally Determined Contribution (PAK-INDC). Islamabad.
13 ADB. 2017. Climate Change Profile of Pakistan. Manila.
6
its annual greenhouse gas emissions by 20% relative to the business as usual level, subject to
the availability of international financial, technological, and capacity building support.14
17. Gender impacts of unreliable electricity supply. Women are the primary managers and
users of electricity in households. The energy crisis adds to women’s time poverty as it increases
the time needed to carry out domestic chores such as cleaning, cooking, and laundry; and reduces
the productivity of home-based workers.15 More than 70% of women work in the informal sector
and are largely associated with small and medium-sized enterprises. From 2017 to 2018, women
comprised 62.1% of home-based workers, and 55% of them are piece-rate workers in
manufacturing.16 Unreliable electricity and long power outages adversely affect their productivity
and livelihood opportunities. Because of their geographic location and hard terrain, the province’s
northern districts are isolated and have lower socioeconomic indicators than the rest of the
province and country. Less reliable energy in the project area further limits women’s opportunities
to participate in economic activities. Improved and reliable electricity supply will boost economic
opportunities for the province’s remote communities, particularly for women.
B. Project Description
18. The project is aligned with the following impacts: carbon footprint reduced; and energy
sector made more renewable, efficient, and reliable.17 The project will have the following outcome:
energy security in Khyber Pakhtunkhwa enhanced.18 A gender-inclusive community development
program will be implemented to mitigate resettlement impacts and build the communities’
resilience against disasters and economic shocks.
20. Output 2: Capacity for climate change risk management in hydropower production
enhanced. Awareness will be developed among communities, with specific training for women
and youth groups to serve as climate change leaders. PEDO staff will be trained to incorporate
climate change risk guidelines into hydropower plant operations.
14 Based on Carbon Brief Paris climate pledge tracker, Pakistan commits to peak and then reduce its emissions.
Specific commitments will be made once “reliable data on our peak emissions levels is available”. Includes paragraph
on adaptation. (footnote 12).
15 ADB. 2016.
Pakistan Country Gender Assessment—Volume 1 of 2: Overall Gender Analysis. Manila.
16 Home Net South Asia. Statistical Brief on Home-Based Workers in Pakistan (2020).
17 Government of Pakistan. 2013. National Power Policy 2013. Islamabad.
18 The design and monitoring framework is in Appendix 1.
7
National Transmission and Despatch Company Limited. This will substantially increase PEDO’s
revenue and will help reduce average daily load shedding in Khyber Pakhtunkhwa.
22. Output 4: Income-earning opportunities and skills for local communities increased.
During construction, the local population will benefit from job opportunities, commercial activities,
and material supply. The project will generate more than 1,200 skilled and unskilled jobs for male
and female workers, of which about 40% will be sourced locally. The project design includes
livelihood skills development for women, who have limited economic opportunities.
23. Building on ADB’s experience in the sector since 2005, the project will help strengthen
PEDO’s strategy to encourage hydropower development in the province. This will contribute to
attaining an energy mix that will not only increase the share of clean energy but also help lower
baseload generation costs.
24. ADB’s value addition comes from the components included in the project design. These
include (i) implementing a gender-inclusive community development program to mitigate
resettlement impacts and build the communities’ resilience against disasters and economic
shocks, (ii) considering climate change impacts in the technical design, (iii) adding extra tiers in
the review of the technical design to help mitigate some of the major implementation risks, and
(iv) incorporating necessary reforms to improve the financial management and sustainability of
PEDO.
25. The project is estimated to cost $755,000,000 (Table 1). Detailed cost estimates by
expenditure category and by financier are included in the project administration manual (PAM).19
exchange costs and 5.2% on local currency costs; includes provision for potential exchange rate fluctuation under
the assumption of a purchasing power parity exchange rate.
d Includes interest, commitment charges, and other fees to be incurred under the ADB and AIIB loans. Interest during
construction for ADB’s ordinary capital resources loan has been computed at the 5-year forward London interbank
19 Project Administration Manual (accessible from the list of linked documents in Appendix 2).
8
offered rate (LIBOR) plus a spread of 0.5% and 0.1% of maturity premium. Commitment charges for the ADB loan
are 0.15% per year to be charged on the undisbursed loan amount.
Source: ADB estimates.
26. The Government of Pakistan has requested a regular loan of $300,000,000 from ADB’s
ordinary capital resources to help finance the project. The loan will have a 27-year term, including
a grace period of 7 years; an annual interest rate determined in accordance with ADB’s London
interbank offered rate (LIBOR)-based lending facility; a commitment charge of 0.15% per year
(the interest and other charges during construction to be capitalized in the loan); and such other
terms and conditions set forth in the draft loan and project agreements. Based on the custom-
tailored repayment method, the average maturity is 16 years, and the maturity premium payable
to ADB is 0.10% per year.
27. The government has also requested a loan not exceeding $280,000,000 from AIIB to help
finance the project. The AIIB loan is expected to have a 22-year term, including a grace period of
7 years; an annual interest rate determined in accordance with AIIB’s sovereign-backed loan
pricing; a commitment charge of 0.25% per year; a one-time front-end fee of 0.25% charged on
the loan principal; and such other terms and conditions to be set forth in the draft loan agreement
between the government and AIIB. ADB will partially administer the AIIB loan.
28. The summary financing plan is in Table 2. ADB and AIIB will jointly finance expenditures
related to the turnkey contract on a cost-sharing basis and the related contingencies and financial
charges during implementation.20 ADB will solely finance consulting services. The provincial
government will finance costs related to taxes and duties, project management, environment and
social mitigation, land acquisition, and a portion of the main turnkey contract. ADB financing will
not be used for costs relating to land acquisition. The proceeds of the ADB loan will be relent to
the provincial government, and through the provincial government will be made available to PEDO
for the purposes of the project.
29. Climate mitigation is estimated to cost $747.97 million and climate adaptation is estimated
to cost $7.03 million. ADB will finance 40% of mitigation and adaptation costs, and AIIB will finance
37%.21 Mitigation costs comprise the construction of the low-carbon hydropower generation plant
with associated infrastructure and capacity building. The project’s carbon dioxide reduction is
estimated at 572,643 tons per year. Adaptation costs comprise (i) capacity building and the
20 Turnkey contract will be jointly financed by ADB and AIIB. As both the loans will not be made effective at the same
time, the ADB loan will be front-loaded and will finance 85% of the turnkey contract, exclusive of taxes and duties.
Once the AIIB loan is declared effective, the share of ADB and AIIB financing will be revised based on the remaining
amounts to be financed for the turnkey contract at the date of effectiveness of the AIIB loan. The estimated financing
percentage is 43% for the ADB loan and 42% for the AIIB loan.
21 Climate Change Assessment (accessible from the list of linked documents in Appendix 2).
9
equipment for strengthened climate change risk management, and (ii) the construction of a flood-
resilient dam wall and associated slope stabilization.
E. Implementation Arrangements
30. The project executing agency will be Khyber Pakhtunkhwa’s Energy and Power
Department. The implementing agency will be PEDO, which will manage procurement and project
implementation. PEDO will set up a dedicated project implementation unit (PIU) and be supported
by project management consultants. Works will be carried out by a turnkey contractor. All
procurement to be financed and all consultant services to be recruited under the ADB and AIIB
loans will follow the ADB Procurement Policy (2017, as amended from time to time) and the
Procurement Regulations for ADB Borrowers (2017, as amended from time to time). The works
contract will be jointly financed by ADB and AIIB. As the AIIB cofinancing will be partially
administered by ADB, universal procurement will apply to all contracts except for the project
management consultant.22 The project is prepared with advance contracting for the turnkey
contract and the consulting services. Retroactive financing of up to 20% of the ADB loan amount
for eligible expenditures incurred up to 12 months before the date of loan signing will be
considered subject to project preparedness and the availability of counterpart funds.
31. Implementation arrangements are summarized in Table 3 and described in detail in the
PAM (footnote 19).
22 ADB. 2015. Enhancing Operational Efficiency of the Asian Development Bank. Manila. Universal procurement was
not applied for the advance actions for the project management consultant because the request for proposal was
issued to the shortlisted firms before AIIB cofinancing was confirmed.
10
ADB = Asian Development Bank; AIIB = Asian Infrastructure Investment Bank; EPC = engineering, procurement, and
construction; NGO = nongovernment organization; PEDO = Pakhtunkhwa Energy Development Organization.
a Jointly financed by ADB and AIIB. Universal procurement will apply to all contracts except for the project management
consultant. The request for proposal for the project management consulted was issued to the shortlisted firms before
AIIB cofinancing was confirmed.
Source: Asian Development Bank.
A. Technical
32. The project was planned in 1995, followed by a feasibility study in 2013. The dam safety
panel hired under ADB transaction technical assistance in 2017 revealed major concerns about
the layout and location. An option analysis and additional investigations were carried out from
2018 to 2019, and the feasibility study was updated to make it sufficient for the turnkey contract.
The area is prone to earthquakes and floods. The parameters for the design, investigations, and
scenarios for earthquakes, landslides, extreme rains events, and induced flows were analyzed,
and stability of the selected design was established. The dam break study shows a high potential
impact category for population and infrastructure. However, the design incorporates features to
prevent catastrophic failure. Climate change impacts were considered during the selection of flood
peak and frequency, sedimentation, and hydropower generation. Flood events will not constitute
a climate change project vulnerability, while flow variations have been considered in hydropower
generation.
33. The proposed 58-meter gravity concrete dam is significantly shorter and equal or better at
the installed capacity of 300 MW than previous options. Overall, the proposed technical solution
is the most cost-effective. The project planning and feasibility study captured information from the
ongoing upstream Suki Kinari hydropower project and the completed downstream Patrind
hydropower project.23 Multistage site investigations, including boreholes, were carried out to firm
up the design and cost and to reduce the risk. The project implementation period, including testing
and commissioning, is adequate. The feasibility study adequately described the additional studies
and measures during design and operation, notably the supplemental geological and geotechnical
investigations for slope stabilization, physical modeling, and three-dimensional modeling for the
turnkey contract.
34. The design proposes Francis reaction-type turbines after an analysis of the hydraulic
variables (gross head, maximum and minimum net head, and foreseen outflow) and the
calculation of the base turbine speed and other parameters for the given installed capacity based
on the hydropower optimization studies. The design also covers the sizing of the main and
auxiliary components of the turbine. A cavern type-powerhouse has been proposed and
comprises three vertical shaft synchronous generators coupled to the Francis turbines. The
project also includes a 500-kilovolt switchyard and its 1.5 km connecting transmission line.
35. The technical solutions do not depart from the systems generally used in the hydropower
stations in Pakistan, and follow the best modern practice in terms of safety. The interconnection
scheme among the plant, the National Transmission and Despatch Company Limited, and the
Peshawar Electric Supply Company networks fulfills the planning and/or design criteria as
required by NEPRA’s Grid Code.24 The technical specifications for the design, manufacture,
23 SK Hydro; and ADB. 2011. Report and Recommendation of the President to the Board of Directors: Proposed Loan
for the Patrind Hydropower Project in Pakistan. Manila.
24 NEPRA. 2005. The Grid Code. Islamabad.
11
installation, and commissioning of the electromechanical equipment are well defined. PEDO
operation and maintenance (O&M) staff are familiar with the proposed design concepts.
36. In the project area, climate change is expected to decrease total winter and spring
precipitation and increase total summer and autumn precipitation relative to historical levels,
leading to (i) increased total annual generation but decreased peaking generation, (ii) increased
magnitude and frequency of flood events, and (iii) increased sediment load (footnote 21). The
feasibility study has confirmed that the dam will be designed to withstand higher peak flood events
and that the project incorporates strengthened climate change risk management in plant
operations, including disaster risk awareness and management, and improved cascade water
resources management.
37. The project is economically viable, with an economic internal rate of return (EIRR) of
14.1%, exceeding the hurdle rate of 9.0%, and an economic net present value of PRs46.3 billion.25
Sensitivity analysis confirmed that the project remains economically viable against the following
adverse circumstances: (i) a 20% increase in investment costs, (ii) a 20% increase in O&M costs,
and (iii) a 20% decrease in output. Results indicated that the project EIRR is above ADB’s hurdle
rate against these adverse shocks, but the EIRR is sensitive to the combined effect of revenue
decline and capital cost escalation.
38. The financial internal rate of return of 5.3% compares favorably with the weighted average
cost of capital of 3.1%.26 Financial viability is gauged by comparing the revenue and cost streams
of with- and without-project scenarios. Sensitivity analysis confirmed that the project’s financial
viability is robust under adverse circumstances. The financial internal rate of return is based on
the estimated average tariff for hydropower generation from similar projects in Pakistan without
escalation. Although NEPRA will determine the project’s actual tariff based on the engineering,
procurement, and construction cost indexed by foreign exchange rate variation, this scenario was
not considered in the financial analysis. The economic and financial analyses incorporated
expected levels and patterns of precipitation and adaptation costs to ensure that project viability
is robust under expected climate changes (footnote 21). PEDO’s operating and financial
sustainability has been strong, with stable profitability, well-controlled O&M, and a low level of
indebtedness.
C. Sustainability
39. Circular debt and liquidity are the major risks to sector sustainability in Pakistan. The
government, in consultation with development partners, embarked on a reform and financial
sustainability program to address the sector’s fiscal, governance, technical, and policy deficits
(footnote 5). The program entails strengthening the governance of sector institutions, rationalizing
prices, reforming tariffs, and reducing subsidies. PEDO is exposed to the same risks as other
GENCOs but with limited impacts, because (i) PEDO’s liquidity and overall exposure to circular
debt is mitigated by the provincial government’s support for the timely reconciliation of payments
for electricity produced and supplied to the national grid; (ii) PEDO’s generation is all based on
hydropower and therefore has no exposure to the fuel supplier’s default; (iii) the CPPA-G settles
all payments to PEDO within the fiscal year, and no debt is carried forward to the next fiscal year;
and (iv) for payments delayed beyond 90 days, PEDO regularly receives penalty payments by
25 Economic Analysis (accessible from the list of linked documents in Appendix 2).
26 Financial Analysis (accessible from the list of linked documents in Appendix 2).
12
the CPPA-G. In the long run, such sector liquidity and payment discipline risks can affect PEDO’s
financial viability. To address these concerns, PEDO’s revenues must be ring-fenced in NEPRA’s
approved cost recovery tariff settings and enforced contractual terms for payments by the CPPA-
G. Both mitigation measures have been covenanted in the project’s loan agreement to support
economic and financial viability. The feasibility-level tariffs for the project are found to be sufficient
for facility maintenance and the sustainable operations for the project life. The project tariff is
within the normal limits for such projects.
D. Governance
40. PEDO’s financial management risk is substantial and its financial management capability
is weak. PEDO’s accounting policies, procedures, and financial reporting have followed federal
accounting and international accounting standards. To comply with its corporate mandate,
PEDO’s accounting and reporting are transitioning from cash to accrual accounting, compliant
with the International Financial Reporting Standards (IFRS). PEDO delayed submitting audited
entity statements for FY2018 and FY2019, which are expected to be completed by March 2021.
Supported by external consultants, PEDO completed its first IFRS adoption for FY2016 and
FY2017. PEDO needs to strengthen institutional capacity and staff skills for IFRS reporting,
financial planning, internal audit, and corporate governance. To strengthen its disclosure quality
and transparency, PEDO prioritized automation of accounts by pilot-testing enterprise resource
planning and capacity enhancement measures, such as recruiting an adequate number of
qualified financial management and accounting staff. Loan covenants have been included to
address this concern from ADB’s perspective.
41. Although PEDO is governed by its board of directors, approval procedures for major
decisions still rest with the provincial government. As part of the ongoing reforms and to enhance
the corporate governance, a corporatization plan for PEDO has been approved by the board of
directors and is being implemented through actions that include (i) reforming its reporting and
disclosures from cash to IFRS-compliant accrual accounting and adopting enterprise resource
planning, and (ii) strengthening its oversight capacity and creating independent audit and risk
management under the supervisory board for operational efficiency control.
42. PEDO’s capacity for procurement, financial management, and project implementation
were assessed and found to be sufficient to manage international procurement and maintain
accounting systems, financial controls, and audit arrangements. Its financial accounting, auditing
rules, and internal control systems follow generally accepted international practices.
43. The overall procurement risk is medium. The procurement of civil works (the turnkey
contract) and consulting services financed by the ADB and AIIB loans follows ADB’s Procurement
Policy and the Procurement Regulations for ADB Borrowers. Universal procurement will apply for
all contracts except for the project management consultant (para. 30). Advance contracting
actions for the procurement of civil works (turnkey contract) used ADB’s standard bidding
documents in open competitive bidding advertised internationally. The executing agency has
gained experience in the procurement of civil works and consultant recruitment from previous
ADB-funded projects. A strong PIU will be fully established, comprising staff familiar with ADB’s
Procurement Policy. Procurement training will also be provided. Project procurement and
implementation will be supported by a team of international consultants.
44. ADB’s Anticorruption Policy (1998, as amended to date) was explained to and discussed
with the government and Khyber Pakhtunkhwa’s Energy and Power Department. The specific
policy requirements and supplementary measures are described in the PAM (footnote 19).
13
45. The poverty, social, and gender assessment carried out during project preparation
revealed that a significant proportion of households lives below the estimated national poverty
line in the project area. One main reason for poverty in the area is the lack of livelihood
opportunities. Of the total population surveyed for the environmental impact assessment (EIA)
and the poverty, social, and gender assessment, 55% were employed and 25% were
unemployed. The project area is susceptible to disasters caused by humans or triggered by
natural hazards, such as earthquakes and flash floods—the area was hit by two earthquakes in
2004 and 2005 (footnote 21). This adds to the local communities’ vulnerability to economic
shocks. To address these issues, a community development program has been developed with
the following features: (i) preference for local communities during construction for unskilled,
semiskilled, and skilled work; (ii) livelihood skills training programs for local communities; and
(iii) training programs to improve the local communities’ capacity to cope with climate change and
disasters caused by humans or triggered by natural hazards.
46. The project is classified effective gender mainstreaming. A detailed gender action plan
was developed based on the findings of the gender assessment.27 Key actions of the gender
action plan are (i) developing and implementing a gender-mainstreamed community mobilization
strategy; (ii) ensuring women’s participation in consultations at all project implementation stages;
(iii) developing and implementing a skills development program for improving livelihood
opportunities, with 50% women’s participation; and (iv) training women and youth groups as
climate change leaders to create awareness and sensitize their communities on issues related to
climate change and to build resilience against disasters caused by humans or triggered by natural
hazards. A nongovernment consulting firm will be hired to assist PEDO in developing and
implementing the community development program.
F. Safeguards
47. In compliance with ADB’s Safeguard Policy Statement (2009), the project’s safeguard
categories are as follows.28
48. Environment (category A). The EIA and environmental management plan (EMP) have
been prepared following ADB’s Safeguard Policy Statement. The EIA includes an assessment of
environmental flows and impacts on aquatic ecology. A critical habitat assessment carried out as
part of the ecology baseline indicated that the project is in a critical habitat because of the
presence of valued aquatic biological resources, including endemic fish species. The Kunhar
River is home to the Alwan Snow Trout, a migratory fish species listed as vulnerable in the
International Union for Conservation of Nature Red List of Threatened Species. The project may
have significant adverse environmental impacts during construction and operation related to
(i) loss of the riverine ecosystem because of inundation by the Balakot Reservoir; (ii) degradation
of the river ecosystem in the low-flow segment downstream of the Balakot dam; (iii) disruption of
the water supply for mountain spring users because of alterations to the natural passage of
springs caused by blasting for tunnels; and (iv) failure of spoil disposal sites, resulting in increased
erosion and sediment load entering the river. However, the project is expected to have significant
positive impacts, including changes in the ecological integrity of the Kunhar River through the
implementation of the biodiversity action plan.
27 Gender Action Plan (accessible from the list of linked documents in Appendix 2).
28 ADB. Safeguard Categories.
14
49. Adequate mitigation measures were incorporated in the project design and will be
implemented through the EMP, which summarizes the organizational requirements and the
management and monitoring plans to ensure that PEDO takes the necessary measures to avoid
adverse effects and maximize the benefits of the project and to operate in conformance with the
applicable laws and regulations of the provincial government and the Safeguard Policy Statement.
The biodiversity action plan was prepared to support PEDO’s corporate commitments on
conserving biodiversity and to meet the requirements of the International Finance Corporation
Performance Standard 6 and the Safeguard Policy Statement. The environmental management
cost has been estimated at $8,726,170 during construction and $782,281 per year during
operation. The project management consultant will monitor the EMP implementation. The PIU will
establish an environmental and social management unit, which will ensure that the project is being
implemented in an environmentally sustainable manner. PEDO’s environmental safeguard
capacity is low. The PIU and the contractor’s personnel will receive training to maintain awareness
of the environmental aspects, impacts, and risks associated with the project and corresponding
controls. PEDO will hire an external monitoring consultant to independently monitor the
contractor’s compliance with environmental and social requirements. The project complies with
ADB’s public disclosure and consultation requirements. Consultations with project stakeholders
were undertaken in April−June 2017 and June−July 2018. The draft EIA was disclosed on the
ADB website on 10 December 2018 and the final EIA was disclosed on 15 November 2019.
50. Involuntary resettlement (category A). The project will require the acquisition of about
33 hectares of land, affecting about 165 households (887 people) in six villages, according to
feasibility study estimates. About 133 households (730 people) will be severely affected and
129 households will be physically displaced. Additional land may be required for the spoil disposal
site. The project will also affect some community and public infrastructure facilities, such as
schools, health clinics, mosques, local roads, and bridges.
51. A draft land acquisition and resettlement plan (LARP) was prepared to address these
impacts, including rehabilitating the affected community and public infrastructure facilities, based
on preliminary surveys and consultations with the affected households. The draft LARP was
disclosed on 29 July 2019. It will be updated during the detailed design phase and notification
(based on Sections 4 and 5 of the Land Acquisition Act, 1894). A livelihood restoration component
under the community development program will be developed to help the affected households
and residents of the affected villages restore and improve their livelihood situation, cope with the
changes, and benefit from the project. Working under the PIU, a nongovernment organization
specializing in community development and facilitation will be engaged for this purpose. The
environmental and social management unit in the PIU will oversee LARP updates and
implementation, with support from the project management consultant and in coordination with
the revenue department. An external resettlement monitor will be engaged and confirm LARP
implementation. No works will commence until full implementation of the LARP and ADB’s
acceptance of the external monitor report.
52. Indigenous peoples (category C). No communities or settlements in the project area are
considered indigenous people. All households in Mansehra belong to Pakistan’s mainstream
population and nobody self-identified or were identified by others as part of a distinct social and
cultural group. The major castes among the affected households are Syed (69%), Akhund Khel
(11%), Gujjar (7%), Qureshi (5%), Awan (3%), and Mughal (1%). None of these are considered
indigenous people.
15
53. Significant risks and mitigating measures are summarized in Table 4 and described in
detail in the risk assessment and risk management plan.29
IV. ASSURANCES
54. The government and PEDO have assured ADB that implementation of the project shall
conform to all applicable ADB requirements, including those concerning anticorruption measures,
safeguards, gender, procurement, consulting services, financial management, and disbursement,
as described in detail in the PAM and loan documents.
55. The government and PEDO have agreed with ADB on certain covenants for the project,
which are set forth in the draft loan agreement and project agreement.
V. RECOMMENDATION
56. I am satisfied that the proposed loan would comply with the Articles of Agreement of the
Asian Development Bank (ADB) and recommend that the Board approve the loan of
$300,000,000 to the Islamic Republic of Pakistan for the Balakot Hydropower Development
Project, from ADB’s ordinary capital resources, in regular terms, with interest to be determined in
accordance with ADB’s London interbank offered rate (LIBOR)-based lending facility; for a term
of 27 years, including a grace period of 7 years; and such other terms and conditions as are
substantially in accordance with those set forth in the draft loan and project agreements presented
to the Board.
Masatsugu Asakawa
President
9 March 2021
29 Risk Assessment and Risk Management Plan (accessible from the list of linked documents in Appendix 2).
16 Appendix 1
implementation in all activities as indicated in the Gender Action Plan (accessible from the list of linked documents in
Appendix 2).
d To be developed and implemented by a NGO under the community development program targeting men and women
in the surrounding areas of the project. The target of 30% for women and girls is based on the gender assessment
data of KPK.
e Trainings to improve livelihood skills development is part of the overall community development program as indicated
1. Loan Agreement
2. Project Agreement
3. Sector Assessment (Summary): Energy
4. Project Administration Manual
5. Financial Analysis
6. Economic Analysis
7. Summary Poverty Reduction and Social Strategy
8. Gender Action Plan
9. Environmental Impact Assessment
10. Resettlement Plan
11. Risk Assessment and Risk Management Plan
12. Climate Change Assessment
13. Contribution to Strategy 2030 Operational Priorities
Supplementary Document
14. Financial Management Assessment