Proposed National Maritime Policy

Table of Contents

  • Introduction
  • Aim
  • Policy Objectives
  • Section I Maritime Trade and Shipping
  • Section II Ports
  • Section III Ship-building and Repair Activities
  • Section IV Maritime Clusters
  • Section V Bio-resource Potential – Sustainable Capture Fisheries and Aquaculture
  • Section VI Ship-recycling Industry
  • Section VII Coastal Tourism
  • Section VIII Marine Pollution and Environmental Preservation
  • Section IX Offshore Hydrocarbon and Usable Mineral Deposits
  • Section X Maritime Ancillary Services
  • Section XI Coastal Zone Risks
  • Section XII Land-Sea Interface Management
  • Section XIII Marine Scientific Research
  • Section XIV Hydrography
  • Section XV Maritime Disciplines and Training
  • Section XVI Coastal Surveillance & Monitoring
  • Section XVII Maritime Security
  • Section XVIII Defence
  • Section XIX Quality of Life in Coastal Regions
  • Section XX Regional Cooperation
  • Section XXI Maritime Coordination at National Level
  • Section XXII Implementation

INTRODUCTION

Pakistan’s entire southern boundary fronts the Arabian Sea, which in turn mingles with the Indian Ocean. The passage of unduly large proportion of the oil trade through the vital adjacent Gulf to our immediate west lends a strategic dimension to our coastal waters. Our coast as well as our adjoining Exclusive Economic Zone (EEZ) furnishes unlimited opportunities in terms of coast-dependant activities (ports & harbours, marine transportation & trade etc), economic activities (capture fisheries, extraction of hydrocarbons, seabed minerals etc), coastal-linked activities (value-added port logistics, ship-building & repairs, submarine cables & pipelines, offshore installations, fish processing etc), coastal service activities (industries, housing, maritime ancillary services etc) as well as recreational activities, together with the booming sector of coastal-cum-eco tourism.

The country’s realization of this vast potential has so far been woefully inadequate. The foremost need is to sear the importance of the sea into our collective consciousness through a well-orchestrated and focused awareness campaign. Exploitation of this rich potential can thereafter be accomplished on the basis of a sound strategy fuelled by painstaking scientific research (in concert with associated international agencies) on all facets of the marine environment and driven essentially by market forces. The state’s role should focus on, though not be limited to, that of a facilitator, coordinator, mediator, catalyst and regulator, whilst ensuring that this spurt in maritime activity is accomplished within the framework of a sustainable marine environment.

The first and only National Maritime Policy of Pakistan had been promulgated on November 30, 2002. A new National Maritime Policy which is dynamic in nature and more receptive to changing trends is direly needed to give a purposeful sense of direction to our coordinated efforts towards realizing our maritime potential. A comprehensive and all-inclusive policy, incorporating all relevant emerging concepts is now not only desirable, but necessary. This policy document is designed to meet such a pressing need.

This policy is applicable to all provinces and regions of Pakistan for implementation by all relevant federal and provincial ministries in respect of functions entrusted and devolved to them under the Constitution of Pakistan and the Rules of Business 1973 as amended from time to time, as well as all relevant federal and provincial organizations and concerned public stakeholders.

AIM

The aim of the national maritime policy is to furnish a framework for the overall growth of all maritime-related activities within an integrated, secure and sustainable environment.

POLICY OBJECTIVES

The prime policy objective is to safeguard and promote Pakistan’s maritime interests in a focussed manner through adherence to the given guidelines. The following subsidiary objectives stem from this:

  • Restructuring of the existing organization in a bid to lay the desired emphasis on maritime issues.
  • Strengthening existing public sector maritime-related organizations like KPT, PQA, GPA, PNSC, KS&EW etc.
  • Giving an impetus to private entrepreneurship and investment.
  • Generating greater maritime awareness amongst the general public.
  • Promoting knowledge and research in various marine disciplines
  • Exploitation of the living and non-living resources of the country’s Exclusive Economic Zone in a sustainable manner.
  • Giving impetus to little known sectors of a maritime economy.
  • Generating job opportunities in existing and emerging maritime sector.
  • Strengthening maritime security through effective monitoring and policing.
  • Ensuring maritime safety.

SECTION I : MARITIME TRADE AND SHIPPING

0101 Maritime trade has been found to be the most cost-effective and most energy-efficient of all modes of transportation. The shipping sector in general should thus be encouraged to realize it’s full potential, inclusive of inland transportation.

0102 The existing shipping inventory of Pakistan needs to be gradually increased in terms of tonnage and also updated to accommodate more double-hulled oil tankers, general cargo ships and container ships in particular. Subject to future demand, passenger ferries and cruise liners can also be considered for procurement in due course.

0103 Though a range of incentives had been offered through the promulgation of the Pakistan Merchant Marine Policy of 2001, it still failed to attract any investment, local or foreign. Pakistan’s credibility with regard to its intent to deregulate the sector and its will to facilitate and effectively implement its commitments, needs to be clearly established beforehand.

SECTION II : PORTS

0201 In keeping with modern global trends, Pakistan’s ports need to move beyond the traditional ship-servicing and cargo handling capabilities to the provision of a progressively increasing range of logistics and value-added services.

0202 Free Trade Zone (FTZ) areas, near to and with direct access to ports, need to be developed in order to attract foreign investment and leading edge technologies. These zones, apart from enabling the vital functions of manufacturing, trade, logistics and distribution under one roof, can also offer the needed fiscal incentives to make them an attractive investment destination.

0203 In order to be competitive and commercially vibrant, Pakistan’s ports need to display a productivity advantage in cargo-handling services, apart from providing a diverse range of highly-integrated services.

0204 Having recognized the vital role of ports as a key component of an uninterrupted supply chain, Port Authorities should focus on charting out realistic plans for a viable development strategy and, while looking after both public and commercial interests, should act as facilitators, mediators and catalysts in order to promote efficiency in the logistics chain.

0205 Pakistan’s three major ports, while in competition with other regional ports for cargo and logistics services, should forge a common strategy to augment those specialized functions for which each is eminently suitable by virtue of location, space, environment and inter-connectivity. Gwadar in particular can accordingly be primarily considered for development as a transhipment port to land-locked countries like Afghanistan and Central Asian Republics and subsequently as a Free Trade Zone to attract investment. The trade needs of the western part of China can also be suitably met.

SECTION III : SHIP-BUILDING AND REPAIR ACTIVITIES

0301 Ship-building and repair activities can receive a considerable boost from an active shipping sector.

0302 Karachi Shipyard & Engineering Works Ltd, which is currently the only enterprise in the country with some level of expertise in this field, should be suitably upgraded in terms of organization, management practices, skilled manpower, infrastructure and capacity to be able to fully exploit the following opportunities on offer

  • Construction of ocean-going vessels for PNSC and other public & private ship-owners
  • Construction of warships for the Pakistan Navy and Offshore Patrol Vessels (OPVs) for PMSA.
  • Construction of harbour crafts like dredgers, tugs, pilot boats, barges, survey vessels, fishing vessels (as per EU-approved specification), survey vessels and other specialized craft for the Pakistan Navy, PMSA, Coastal Guard, KPT, PQA, GPA, any other principal / secondary port, and other public and private sector customers.
  • Going on to seek foreign ship-building orders

0303 The availability of a ship lift and transfer system at KSEW Ltd which vastly facilitates its capacity and capability to carryout repair and maintenance of all types of craft should be optimally exploited. Apart from going on to meet all the repairs / maintenance requirement of all Pakistani vessels, KSEW should endeavour to seize a sizable chunk of the regional market for such activities.

0304 Foreign investment should also be sought in the setting-up of ship construction & repair facilities at suitable locations along the coast by offering the necessary incentives.

SECTION IV : MARITIME CLUSTERS

0401 All types of maritime – related enterprises, and even research centres, should be encouraged with effective Govt support to form maritime clusters, which would help to develop a knowledge base through skill-sharing, and create business opportunities for maritime-related activities and expand employment prospects.

0402 Such clusters can boost the development of the maritime sector by including multifarious maritime activities like manufacturing, warehousing, transportation, maintenance / repair, wholesale trade, engineering services, training and water-based recreation.

0403 Apart from Governmental support, which should be forthcoming, creation of a good infrastructure and access is essential.

SECTION V : BIO – RESOURCE POTENTIAL – SUSTAINABLE CAPTURE FISHERIES AND AQUACULTURE

0501 Fisheries in Pakistan has the potential of developing into a multi-billion dollar industry while generating employment opportunities for over a million families. A direct and indirect assessment of bio-resource potential in Pakistan’s maritime areas is essentially required.

0502 As a first step towards fisheries encouragement, scientific studies should be conducted to collect reliable and accurate data to assess the status of fisheries and ecosystems, including data on by-catch, discards and waste, and subsequently develop the capability to monitor and assess the state of the stocks, in line with FAOs Code of Conduct for Responsible Fisheries 1995. Lack of information on the number of fish stocks available or any potentially endangered species is inconducive towards formulation of a meaningful capture fisheries policy.

0503 All studies conducted have indicated a depletion of fish stocks in Pakistan’s EEZ, with deep sea fishing trawlers being responsible for a major part of this carnage. The current practice of permitting foreign deep-sea trawlers to operate in our EEZ needs to be discarded on the following grounds:

  • This method of fishing is indiscriminatory, thereby affecting sustainability.
  • Industrial fishing, using at times measures deemed illegal by the FAO, tends to destroy the spawning grounds, thereby affecting the livelihood of all those involved in the small-scale local fishing sector.
  • Once a license is granted, it becomes difficult to accurately monitor and check whether the said vessels or any other rogue vessel is using illegal methods, carrying out transhipment of catch on the high sea, underinvoicing fish catches, discarding huge quantities of young, unwanted or dead fish, fishing in areas closer to the coast under cover of darkness or on the pretext of proceeding to harbour etc.

0504 Legislation against all forms of Illegal, Unreported and Unregulated fishing should be strictly implemented through strengthening of our surveillance, monitoring and apprehension capabilities.

0505 Ban on all destructive forms of fishing like pelagic drift net fishing, bull trawling, bottom trawling, use of fine mesh fishing nets etc should be strictly implemented in a bid to ensure conservation and management of objectives. Creeks which are natural fish hatcheries should be protected at all costs.

0506 The state should initially play it’s role in the gradual enhancement of our fishing capability through capacity-building of the traditional fishermen to man larger sea-going vessels to be built in-country under approved specifications. These fisherfolk and their children should be educated to appreciate the value of safe practices in the use and management of fishery resources for long-term gains.

0507 Quality, capacity and hygiene problems which have resulted in a lingering ban on seafood exports to the European Union should be properly attended to, to enable the continuation of such exports.

0508 All fish harbours should be appropriately upgraded and restructured at par with international standards.

0509 The issue of over-fishing should also be tackled, with ‘Marine Protected Areas’ being promulgated as and when necessary.

0510 Faced with the future prospect of depleting fish stocks, aquaculture should be encouraged on a larger scale to adequately make up the shortfall and provide a valuable source of livelihood and nutrition to many. The advantages offered by mariculture in particular needs to be capitalized upon.

0511 The greatest harm perpetrated by far on the livelihoods of local fisherfolk is by pollution through sewerage, industrial effluents, discharges from oil refineries / tanker berths, oil spills etc which needs to be minimized for the sake of preservation of Pakistan’s coastal ecology and biodiversity.

SECTION VI : SHIP-RECYCLING INDUSTRY

0601 After a relatively long period of stagnation in the nineties, Pakistan’s ship-recycling industry is flourishing again. Its strong regional advantage, namely it’s proximity to the Gulf where a vast number of large vessels are being laid off, is being and needs to be capitalized upon. As long as local demand of ship billets continues to outpace supply, the industry should continue to enjoy a bright future. Owing to the large number of workers being employed in the industry and it’s spin-offs, as well as the large revenue being generated through a profitable commercial activity, federal and provincial government’s patronage is vital to its continued success.

0602 Major problems being faced at the sole ship-breaking yard at Gadani include a lack of requisite infrastructure, access roads, electricity, drinking water, health facilities etc, which needs to be redressed on priority basis to enable the industry to fully realize it’s potential. Environmental and pollution issues associated with the industry should be given due weightage.

SECTION VII : COASTAL TOURISM

0701 Coastal tourism along with its offshoot eco-tourism, is the most dynamic and rapidly expanding economic sector in the world today. Pakistan, possessing a relatively long coastline with pristine beaches, is ideally placed to capitalize on this trend. The private sector should be encouraged to exploit the economic opportunities on offer by assuring it of the Government’s all-out support. Water sporting activities should also be encouraged.

0702 It needs to be kept in mind, however, that foreign tourists would only be attracted if they see the following pre-requisites being met:

  • Necessary tourism infrastructure, properly sited and with good public access.
  • Further coastal development like resorts, theme parks, hotels, restaurants, food industry, vacation homes, second homes etc.
  • Recreational activities like cruises, boating, swimming, surfing, jet skiing, fishing, scuba diving, snorkeling, marine shows, submersible experiences etc.
  • Supporting infrastructure for the above like recreational boating harbours, piers, promenades, recreational fishing piers / facilities, beaches, retail businesses, marinas, marine equipment stores etc
  • Relatively liberal regime
  • Good law & order situation
  • Good marketing strategy
  • Security from risks associated with natural hazards
  • Healthy coastal habitats with beautiful living marine resources
  • Relaxed and enjoyable environment
  • Regular beach maintenance to ensure its amenity value
  • Requisite safety measures

0703 Ecotourism in marine and estuaries protected areas possesses great potential that needs to be exploited in tandem with coastal tourism.

SECTION VIII : MARINE POLLUTION AND ENVIRONMENTAL PRESERVATION

0801 Marine Pollution is the scourge of any form of meaningful maritime activity because of its exceedingly unhealthy environmental impact. Pollution of Pakistan’s seas and oceans through industrial discharges, accidental spills, marine debris and urban / agricultural wastes has literally devastated marine life, either directly or through loss of habitats. Though pollution from shipping, sea dumping and oil spills off Pakistan’s coast is rampant, it is the pollution from land-based sources, agricultural nutrients, industrial effluents and untreated sewage in particular, that poses the greatest threat to the marine environment and biodiversity.

0802 Both the rapidly growing population and the even larger human imprint needs to be focused upon, if our bid to minimize this environmental hazard is to succeed. Strict adherence to international conventions on the subject, environmental safety standards and safe practices is essential in order to preserve our marine environment and marine biodiversity.

0803 Pakistan’s capacity to handle accidental oil spills as well as deliberate effluent discharges from traversing, berthed and anchored vessels should be strengthened in all respects. Illegal discharges of ballast water should be curbed.

0804 Preservation of mangroves and natural habitats should be accorded the highest priority as they are critical to the effective functioning of the coastal ecosystem.

SECTION IX: OFFSHORE HYDROCARBON AND USABLE MINERAL DEPOSITS

0901 It has long been recognized that the oceanic potential of offshore hydrocarbons and useable mineral deposits is much more than the continental one. These include iron, manganese nodules and crusts, oil, gas and gas hydrates, with the latter having all the trappings of evolving into a very useful source of clean energy.

0902 Preliminary scientific indicators point to the presence of large deposits of gas hydrates off the coast of Balochistan. Technological constraints, however, need to be overcome through dedicated and sustained research and exploration programmes, that would enable the country to fully exploit these offshore hydrocarbon reserves and usable mineral deposits without any wastage.

SECTION X : MARITIME ANCILLARY SERVICES

1001 A thriving maritime industry will give rise to ancillary services such as insurance, banking, brokering, classification, consultancy etc, all of which are important in their own right and will lead to various job opportunities and commercial possibilities. Preparatory measures in terms of capacity building need to be undertaken.

SECTION XI : COASTAL ZONE RISKS

1101 The coastal zone is particularly vulnerable to natural risks like storms, tsunamis, erosion and man-made hazards like pollution, climate change, smuggling, piracy, transnational crimes, terrorism, proliferation etc.

1102 Plans should be in place to manage and counter eventualities like oil spills, groundings and storms while illegal activities like land and ship-based pollution, poaching, smuggling, terrorism and piracy should be continuously monitored and strongly countered.

SECTION XII : LAND-SEA INTERFACE MANAGEMENT

1201 The linkage between the sea and its adjoining land is deep and undeniable. For one thing, the marine eco system off our eastern coast is preserved by the flow of water from the River Indus down to the Arabian Sea. For another, land-based sources are the major cause of the pollution that affects our marine environment. It is also obvious that all sea-based activities, whether pertaining to maritime trade or exploitation of living and non-living resources or marine renewables or recreational activities, require a land-based infrastructure.

1202 An integrated approach for the management of the coast is thus essential for it’s sustainable development as an indivisible entity. Government agencies, private sector and members of the wider public, all need to collaborate in the preparation and implementation of a consolidated plan. The approach needs to move beyond typical land-based thinking in order to cater to policy, capacity, environmental, sectoral, zoning and administrative issues of both the terrestrial and marine components.

1203 The concept of Integrated Coastal Zone Management (ICZM) has by now proved itself to be a viable one and needs to be adopted to suit Pakistan’s own peculiar conditions.

SECTION XIII : MARINE SCIENTIFIC RESEARCH

1301 Now that Pakistan’s case for extension of its continental shelf to 350 nm has been filed prior to the given deadline, the more painstaking business of realizing the full potential of the EEZ and continental shelf deserves to be given serious thought. The expertise as well as data acquired during the process should provide a firm foundation for future marine research.

1302 Scientific research in the fields of biotechnology, marine renewable energy, exploitation of methane hydrates and usable mineral deposits, collection of reliable / accurate data for assessing the status of fisheries / ecosystems etc should be given priority.

SECTION XIV : HYDROGRAPHY

1401 Importance and demand of hydrographic activities is on the rise. The challenges of safe navigation and safety of life at sea has increased the level of commitment and responsibilities of the coastal states. Pakistan being a coastal state and signatory of UNCLOS’82 is obliged to extend hydrographic services to the international maritime community as defined in SOLAS (Chp V, Reg 9). Pakistan Navy Hydrographic Department (PNHD), being the National Hydrographic Office, is accordingly responsible to meet all national & international hydrographic requirements, provide technical advice on matters related to hydrography & associated fields, assist in delimitation of maritime boundaries and establishment of chart datum along the coast. Hydrographic information acquired by PNHD should be used to facilitate coastal zone management, exploration, marine sciences, descriptive oceanography, national spatial data infrastructure, maritime defence, tourism and recreational activities. PNHD should continue to shoulder it’s international responsibilities as an area coordinator for NAVAREA IX to promulgate navigational warnings in the Arabian Sea, Persian Gulf and Red Sea region.

1402 Pakistan, as a coastal state and member of various maritime organizations like International Maritime Organization (IMO) and International Hydrographic Organization (IHO), should continue to strengthen it’s hydrographic set-up wrt status, services on offer, capabilities and capacity – building to fulfil it’s national and international commitments.

SECTION XV : MARITIME DISCIPLINES AND TRAINING

1501 A National Maritime University needs to be set up, which would have under its wing, directly or indirectly, the essentially needed maritime disciplines of naval architecture & ship-building, marine engineering, nautical services, sea transportation / logistics, maritime law, oceanography, climate change, dredging, port & maritime management, marine scientific research, fisheries research etc. This would also hopefully improve the training standards of our seafarers.

SECTION XVI: COASTAL SURVEILLANCE AND MONITORING

1601 A lot of unwanted activities take place off Pakistan’s coast but go unnoticed because of a visible lack of coastal surveillance and monitoring effort. These include IUUF (Illegal, Unregulated and Unreported Fishing), marine pollution through merchant / fishing vessels and human/narco-smuggling. While accidental oil spills can wreak havoc on a vast scale, deliberate discharges of effluents on a sustained basis can be equally debilitating. Compliance of all international conventions as well as the Pakistan Merchant Shipping (Carriage of Hazardous and Dangerous Substances by Ships) Rules 2009 for the regulation of carriage of hazardous and dangerous substances in ships, also needs to be ensured.

1602 A network of coastal surveillance system, patrol aircraft and sea vessels, utilizing all available resources of the Pakistan Navy, Pakistan Air Force, Pakistan Maritime Security Agency and Coast Guards along with a shore-based collation centre, should be energized to maintain vigilance and discourage vessels from flouting international conventions on poaching and pollution in particular.

1603 It should be ensured through careful monitoring that all vessels traversing our EEZ should be MARPOL 73/78 compliant. Use of harmful anti-fouling systems and ship’s ballast in violation of international conventions should be curbed while poachers at sea should likewise be nabbed.

SECTION XVII : MARITIME SECURITY

1701 Maritime Security has taken on an added urgency in recent years. The measures agreed to under the recently enforced (July 1, 2004) International Ship and Port Facility Security Code (ISPS) by all signatories of the earlier SOLAS Convention, need to be fully implemented. Compliance of these measures, in particular the Ship Security Alert System, the Shipborne Automatic Identification System and in general all standardized risk management procedures, is mandatory for Pakistan as one of the contracting parties to the earlier SOLAS Convention. In addition, the ILO/IMO Code of Practice on Security in Ports with respect to security of the wider port area, as well as the Seafarer’s Identity Documents Convention (Revised) 2003 also need to be complied with. All possible measures should be undertaken to ensure the safety of our ports, shipping and line of communications.

SECTION XVIII : DEFENCE

1801 A flourishing maritime industry and trade generates all manner of seaward threats, both conventional and asymetric. These need to be countered by systematically strengthening our preparation and response levels.

1802 Pakistan’s surveillance and strike capabilities should accordingly be enhanced to serve as a credible deterrence.

SECTION XIX : QUALITY OF LIFE IN COASTAL REGIONS

1901 On a global basis, the coastal regions are linked with far greater population density ( almost 10:1 in comparison with inland regions), productivity and amenity value. In Pakistan, apart from the Karachi Metropolitan Area, the coastal belt ranks poorly in all departments. The quality of life in Pakistan’s coastal regions should be visibly improved in all respects.

1902 A large part of Pakistan’s coastline is still pristine and sparsely-populated and offers vast opportunities for development which should be undertaken in a zoned, integrated, controlled and sustainable manner.

SECTION XX : REGIONAL COOPERATION

2001 A high level of regional cooperation needs to be maintained through mutual understanding, bilateral agreements or as members of littoral groupings. Apart from knowledge and skill-sharing, issues like maritime boundaries, pollution control, sustainable fisheries, poaching, offshore infrastructure etc demand regional solutions through discussions and accommodation of each other’s perspectives.

SECTION XXI : MARITIME COORDINATION

2101 Al present, coordination of all maritime affairs at national level is being handled by the National Maritime Affairs Coordination Committee, whose composition is as under:

Secretary Defence

Chairman

Secretary Cabinet Division

Member

Secretary Interior Ministry

Member

Secretary Finance Ministry

Member

Secretary Foreign Affairs Ministry

Member

Secretary Planning & Development Ministry

Member

Secretary Communication & Railways Ministry

Member

Secretary Ports & Shipping Ministry

Member

Secretary Food & Agriculture Ministry

Member

Secretary Climate Change Ministry

Member

Secretary Petroleum & NR Ministry

Member

Secretary Livestock & Dairy Development

Member

Secretary Science & Technology

Member

Secretary Economic Affairs Division

Member

Vice Chief of Naval Staff

Member

Chief Secretary, Government of Sindh

Member

Chief Secretary, Government of Balochistan

Member

Executive Director HEC

Member

Managing Director KS & EW

Member

Director General Pakistan Maritime Security Agency

Member

General Pakistan Coast Guards

Member

 

2102 While this committee can look into matters of policy, it is unwieldy & unsuited to carry out the routine day to day coordination required in maritime matters.

2103 A National Maritime Authority should accordingly be set-up with the mandate of coordinating all relevant maritime-related issues under one roof, relating in particular to sea trade, marine pollution, maritime security, fisheries, coastal tourism, coastal zone management, search & rescue, marine aids to navigation, vessel surveys, seafarers certification etc.

2104 The only Ministry exclusively tending to a maritime issue is that of Ports & Shipping. The proposed National Maritime Authority can only serve a useful purpose if it comes under a single Ministry coordinating all maritime matters. A Ministry of Maritime Affairs which directly handles the important maritime subjects of ports, shipping & coastal zone management while indirectly coordinating all other maritime aspects, needs to be constituted.

SECTION XXII : IMPLEMENTATION

2201 Policy guidelines are being promulgated through this document.

2202 It’s implementation is to be ensured through the following phased process:

  • Implementation guidelines – through National Maritime Strategy, which will be approved and promulgated after following the same process as for the National Maritime Policy.
  • Assigning responsibilities and targets – by NMACC.
  • Monitoring, assessment, periodical review and adjustment – by NMACC.

2203 The proposed Ministry of Maritime Affairs as well as the proposed National Maritime Authority would only be responsible for handling and coordinating specific tasks as assigned in the National Maritime Strategy. MoD/NHQ would continue to have a major say in all matters related to maritime defence and security.

2204 These policy guidelines are equally applicable to provincial administrations in respect of the subjects which have been devolved to the provinces.

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