{"data":{"id":"sbm393ac8df38d96a1bf9fed","short_id":28,"created":"2025-11-21T04:33:31.448Z","space_id":"spc38bf5a4130666a5ccd765","project_id":"prj38bdad552e555e1c7f990","org_id":"org20ee740c8b3c21feb3566","content":{"zovp5q48":"ENGIE","do-you-agree-to_8cb784":"yes_i_agree","upload-a-submiss_9dbd27":"fil39ca9ca7d4dc5d6bd2dbb"},"is_topic":false,"title":null,"count_replies":0,"closed":false,"reply_to_id":null,"last_activity":null,"reactions":{},"_files":{"fil39ca9ca7d4dc5d6bd2dbb":{"id":"fil39ca9ca7d4dc5d6bd2dbb","bucket":"files-au-climate","remote_path":"climate-au/p/prj38bdad552e555e1c7f990/submission/spc38bf5a4130666a5ccd765/PUBLIC_20251121_ENGIE_submission_Solar_Sharer_Offer_Consultation_Paper_Redacted.4f904746.pdf","url":"https://storage.googleapis.com/files-au-climate/climate-au/p/prj38bdad552e555e1c7f990/submission/spc38bf5a4130666a5ccd765/PUBLIC_20251121_ENGIE_submission_Solar_Sharer_Offer_Consultation_Paper_Redacted.4f904746.pdf","filename":"PUBLIC - 20251121 - ENGIE submission - Solar Sharer Offer Consultation Paper_Redacted.pdf","transcribed":"Add\n\nRetail Market Policy team\nDepartment of Climate Change, Energy, the Environment and Water\nGPO Box 3090\nCanberra ACT 2601\n\n[note – confidential information has been removed]\n\n21 November 2025\n\nTo Retail Market Policy team,\n\nSolar Sharer Offer (SSO) – Consultation Paper 2025-26\n\nENGIE Australia & New Zealand (ENGIE) appreciates the opportunity to respond to the Department of\nClimate Change, Energy, the Environment and Water (the Department) on its consultation on the design of a new Solar Sharer Offer (SSO) standing offer tariff.\n\nThe ENGIE Group is a global energy operator in the businesses of electricity, natural gas and energy services. In Australia, ENGIE operates an asset fleet which includes renewables, gas-powered generation, and battery energy storage systems. ENGIE also provides electricity and gas to retail customers across\nVictoria, South Australia, New South Wales, Queensland, and Western Australia.\n\nENGIE is supportive of the intent of the SSO reform to support households to benefit from cheaper daytime renewable electricity. Since 2014, when the Australian Energy Market Commission (AEMC) first required distribution network service providers (DNSPs) to introduce cost-reflective network prices1, the industry has had a focus on incentivising households through time-of-use (TOU) pricing to change their consumption behaviour and save money on their bills by using more electricity during off-peak periods. However, as the\nAEMC has previously highlighted, many households may be unable or unwilling to respond to TOU price signals and may not benefit from being supplied on TOU electricity offers.2\n\nAs the SSO is being designed as a TOU standing offer, ENGIE considers the same issues identified with TOU pricing over the past decade will also likely apply to the SSO. As households on standing offers are typically less actively engaged in understanding their energy consumption than other households, these households may not be well positioned to benefit from a TOU pricing structure. If the SSO is not carefully communicated and targeted, the introduction of the SSO may not achieve its desired policy objectives and instead result in less affordable electricity bills for low-income households.\n\n1\nAustralian Energy Market Commission 2014, New rules for cost-reflective network prices, Media release, available at: https://www.aemc.gov.au/news-centre/media-releases/new-rules-for-cost-reflective-network-prices\n2\nAustralian Energy Market Commission 2024, Accelerating smart meter deployment – Directions paper, 15 August, p. 4. Page 1\nFrom the perspective of a retailer, the introduction of the SSO may create cost risks due to mismatches between the SSO tariff structure and the underlying network tariff structures, which do not provide a zero-charge usage window. The risks for retailers during the zero-charge usage window may be significant if the SSO is primarily taken up by very engaged customers that seek to use their battery storage to take advantage of free retail electricity in the middle of the day. It is critical that the Australian Energy Regulator\n(AER) is instructed to set SSO tariff structures that allow retailers to recover their efficient costs of providing the SSO, based on a relevant model annual usage profile that reflects the Department’s expected shift of demand into midday hours.\n\nIt is disappointing that the Department announced the implementation of the SSO without prior consultation and understanding of industry readiness for the reform. The introduction of a new standing offer that will be available alongside existing standing offers will have significant system build costs and complexities for retailers, particularly for those retailers not currently selling an equivalent market offer with a ‘free power period’. It will not likely be feasible for most retailers to compliantly offer the SSO to households by 1 July 2026, particularly as there is not yet clarity on when the final tariff structure design and supporting requirements will be communicated to retailers.\n\nTo address the issues summarised above, ENGIE proposes the Department consider an alternative implementation approach for the SSO that initially commences with a limited trial of the SSO for specific customer cohorts (for example, the customers the policy is primarily seeking to benefit3 – renters, apartment dwellers and low-income households). This alternative approach may:\n\n• Ensure that the SSO is designed for the customer cohorts it is intended to benefit, namely those that\nare unable access solar and battery storage;\n\n• Reduce the costs of facilitating an SSO, by requiring retailers to develop a targeted offer rather than\nimplementing significant system changes to support wider availability;\n\n• Enable distribution businesses to facilitate a harmonised tariff structure through tariff trials of network\ntariff structures with zero-charge usage periods;\n\n• Provide for evaluation and monitoring of the outcomes for households on the SSO relative to\nalternative offers, as well as the cost recovery for retailers when supplying the SSO.\n\nThe remainder of this submission provides more detailed feedback on the design and implementation of the SSO and ENGIE’s recommended alternative approach. ENGIE welcomes further opportunities to engage and collaborate with the Department on workable alternative SSO implementation approaches. Should you\n\n3\nDepartment of Climate Change, Energy, the Environment and Water 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 21.\n\nPage 2\nhave any queries in relation to this submission please do not hesitate to contact me on, telephone,\n.\n\nYours sincerely,\n\nMatthew Giampiccolo\nManager, Regulation and Policy\n\nPage 3\nDetailed feedback to Solar Sharer Offer (SSO) – Consultation Paper 2025-26\n\nIn the below sections, ENGIE provides further detail on:\n\n• The risks consumers may face from TOU tariff structures;\n• The benefits of harmonising retail and network tariff structures for the SSO;\n• The importance of the SSO being designed to ensure retailers are able to recover their efficient costs;\n• The challenges in meeting the proposed implementation timeframe for introducing the SSO; and\n• An alternative implementation approach for the SSO, through an initial limited and targeted trial.\n\nThere are demonstrated consumer risks with TOU tariff structures\n\nENGIE agrees with the Department’s concerns in the consultation paper that while consumers may be attracted to the marketing of ‘free’ electricity in offers with ‘free power periods’, they may not be able to change their consumption behaviour to benefit from the ‘free’ electricity and may actually end up paying higher electricity bills.4 The reliance on consumers’ changing their behaviour in response to price signals has been a common concern with the effectiveness of time-of-use (TOU) tariff structures since their introduction in 2014. Relevantly, from December 2025, prohibitions will be introduced on retail tariff reassignments following a smart meter installation due to concerns that many households may be unable or unwilling to respond to TOU price signals and may not benefit from being supplied on TOU electricity offers.5\n\nThe Australian Energy Market Commission’s (AEMC) ongoing Pricing Review is considering the preferences of future consumers and how retail offerings should be designed to meet the diverse needs of consumers, both with and without consumer energy resources (CER). In feedback to the Pricing Review, several consumer groups emphasised that most consumers want a simple and affordable flat-rate energy product.6\nThe South Australian Council of Social Service (SACOSS) raised specific concerns with TOU tariffs, such as the complexity for households and that peak period rates can be unavoidable and punitive.7 SACOSS also stated that there has been no evidence that TOU price signals have been effective at changing behaviour or reducing electricity prices for consumers.8\n\nIn its submissions to the Pricing Review, ENGIE expressed similar feedback to consumer groups and has advocated for network tariff reform to introduce a simple tariff structure, potentially with a fixed and flat\n\n4\nDepartment of Climate Change, Energy, the Environment and Water 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 15.\n5\nAustralian Energy Market Commission 2024, Accelerating smart meter deployment – Directions paper, 15 August, p. 4.; and\nAustralian Energy Market Commission 2024, Accelerating smart meter deployment – Rule determination, 28 November, p. 31.\n6\nEnergy Consumers Australia 2025, Submission to ‘The pricing review: Electricity pricing for a consumer-driven future, 10 July, p. 3.;\nJustice and Equity Centre 2025, Submission to ‘The Pricing Review: Discussion Paper, 10 July, p. 6; and\nSouth Australian Council of Social Service 2025, SACOSS’ Submission to the Australian Energy Market Commission’s Discussion Paper on the Pricing\nReview, July, p. 10.\n7\nSouth Australian Council of Social Service 2025, SACOSS’ Submission to the Australian Energy Market Commission’s Discussion Paper on the Pricing\nReview, July, pp. 10-11.\n8\nIbid. Page 4\nvolumetric component, that would provide a basis for retailers to develop a suite of retail tariff offerings that align with the needs of different customer cohorts, including a basic service offering available at a reasonable price.9 ENGIE also agrees with feedback from Energy Consumers Australia (ECA) that uniform\nTOU network tariffs are likely to be less effective than the introduction of targeted locational signals or rebates.10\n\nENGIE is concerned that the introduction of the SSO will entrench a new TOU tariff structure in the electricity retail market, which may drive the same types of consumer issues that have been identified with other TOU pricing arrangements over the past decade. The types of households that are intended to be the primary target customer base for the SSO, particularly low-income households, may be those least able or willing to change their energy consumption behaviour in response to a TOU pricing signal. To the extent that low-income households are able to change their energy consumption, this may be to the detriment of their health if they are relying on cost savings due to changes in their use of heating and cooling. Relevantly,\nECA published information on consumer responsiveness to price signals earlier this year, which suggested that low-income households may be more likely to adjust their use of heating and cooling in response to\nTOU prices and that low-income households have less ability to benefit from their response to TOU prices.11\n\nWhile the SSO provides opportunities for the target customer base, much like existing TOU offers, there are also risks that these households are not able to align their energy consumption with the zero-charge usage window and actually experience less affordable electricity bills.\n\nRetailers may be exposed to significant cost risks without a harmonised network tariff structure\n\nAround 40 per cent of a household’s electricity bill is comprised of network costs12, with this proportion expected to continue to increase and represent around half of a household’s annual electricity bill by\n2034.13 Unlike wholesale costs, which also represent around 40 per cent of a household’s electricity bill14, retailers do not have any tools to hedge against the variability of network tariffs on behalf of their customers. Typically, new tariff structures are developed by distribution network service providers (DNSPs) to more accurately reflect the costs of serving their customers. In most cases, retailers will align their retail tariff structures with network tariff structures to avoid the risks of not recovering this significant cost component from customers.15\n\n9\nENGIE 2025, Submission to ‘The pricing review – Discussion paper, 10 July, p. 6.\n10\nEnergy Consumers Australia 2025, Submission to ‘The pricing review: Electricity pricing for a consumer-driven future, 10 July, p. 15.\n11\nEnergy Consumers Australia 2025, Consumer knowledge of electricity pricing and responsiveness to price signals, January, p. 9.\n12\nAustralian Energy Market Commission 2025, The pricing review – Discussion paper, June, p. 17.\n13\nAustralian Energy Market Commission 2024, Residential electricity price trends 2024, November, p. 12.\n14\nAustralian Energy Market Commission 2025, The pricing review – Discussion paper, June, p. 17.\n15\nAustralian Competition and Consumer Commission 2024, Inquiry into the National Electricity Market: June 2024 Report, 3 June, p. 61. Page 5\nAs the SSO is being introduced through government policy, DNSPs do not currently have supporting network pricing arrangements that align with the proposed SSO design. For example, while SA Power\nNetworks (SAPN) provides a ‘solar sponge’ off-peak rate from 10am to 4pm in its TOU network tariff, this is currently charged at a rate of $0.0474 per kWh to retailers.16 ENGIE agrees with the Department’s comments in the consultation paper that harmonising the SSO structure with network tariff structures would maximise benefits and minimise complexity of the SSO.17 As noted above, without a corresponding network tariff structure that provides a zero-charge usage window for retailers, supplying the SSO may expose retailers to significant network cost risks, particularly if there were a large behavioural response from engaged consumers to shift significant electricity consumption to the SSO’s zero-charge usage window.\n\nENGIE is advocating for each DNSP to introduce an SSO-equivalent network tariff with a zero-charge usage window, which would minimise the risk of significant costs accruing to retailers due to tariff mismatches.\nHowever, ENGIE acknowledges that there are barriers in re-opening DNSPs’ Tariff Structure Statements\n(TSS) during a five-year revenue determination period to introduce a new tariff structure. As an alternative to re-opening a TSS, rule 6.18.1C of the National Electricity Rules enables DNSPs to develop tariff trials, which allows a DNSP to introduce tariffs not covered by its TSS. However, tariff trials have limited application and only permit the introduction of tariffs that do not recover more than 0.5 per cent of the\nDNSP’s annual revenue requirement. As will be discussed later in this submission, ENGIE contends that tariff trials may be able to be utilised if the SSO is initially introduced as a limited trial to test the design and viability of the SSO before a wider implementation.\n\nIn its role to set the SSO, the AER must ensure that retailers can recover their efficient costs\n\nThe Department should provide the Australian Energy Regulator (AER) with clear direction on the matters it must take into account when determining the SSO and the specific design of the zero-charge usage window.\nIn addition to the long-term interests of consumers, it is particularly important that the AER considers the efficient costs of retailers supplying small customers on the SSO, including a margin and modest costs associated with customer acquisition and retention.\n\nENGIE agrees with the proposed criteria that consumers are charged a ‘reasonable price’ for consumption outside of the zero-charge usage window.18 However, ENGIE contends that this ‘reasonable price’ must be based on the costs to supply customers both inside and outside of the zero-charge usage window, noting that retailers will still incur variable network, wholesale hedging, and environmental costs for consumption inside the zero-charge usage window.\n\nENGIE notes that there is a real risk that the SSO is primarily adopted by higher-income and savvy consumers that seek to maximise the value of their battery storage by fully charging their batteries with\n\n16\nSA Power Networks 2025, Initial Pricing Proposal Overview 2025-26, May, p. 37.\n17\nDCCEEW 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 18.\n18\nDCCEEW 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 25. Page 6\nfree retail electricity in the zero-charge usage window. If this risk is not managed, such as through a ‘fair use’ policy to limit consumption allowable in the zero-charge usage window or restrictions on eligibility, retailers may significantly under-recover their costs of supplying the SSO.\n\nENGIE considers that when setting the SSO, the AER should be required to apply a bespoke annual usage profile based on the expected shifts in consumption behaviour. As the AER’s existing usage profiles are based on historical Australian Energy Market Operator (AEMO) interval meter data, relying on this data to determine the SSO tariff structure may significantly understate the shift in consumption and may expose retailers to a substantial under-recovery of their efficient costs. When determining an appropriate model annual usage profile for the SSO, the AER may consider obtaining information from retailers currently providing offers with ‘free-usage windows’19 to understand the extent that consumption has shifted to these high solar generation periods.\n\nWhen determining the timing of the SSO’s zero-charge usage window, the AER will need to consider the application of daylight savings times and the impact on the timing of the window. If the timing of the zero-charge usage window is primarily intended to align with periods of highest solar generation, it may be appropriate that different times apply in daylight and standard time periods.\n\nIt will be challenging to make the necessary system and process changes in time for 1 July 2026\n\nAs there are not currently clear timeframes on when retailers will be informed of the final SSO design and requirements, it will likely be very challenging for most retailers to build compliant system changes to be able to offer the SSO by 1 July 2026. Earlier engagement with industry would have been helpful for the\nDepartment to better understand the system changes required to support the SSO and the reasonable timeframes for those system changes. Examples of information that must be determined before retailers can build system and process changes to support the SSO include:\n\n• The specific tariff structure of the SSO standing offer;\n\n• The network tariff arrangement that will underpin the SSO standing offer;\n\n• The process for consumers to transfer to and from the relevant network tariff arrangement. In\nparticular, consumers will require a simple and streamlined process to request reassignment to the\nrelevant network tariff code and a process for reassignment to alternative network tariff codes when a\nconsumer either leaves the premise or opts-in to an alternative retail pricing structure;\n\n• Requirements for any new customer communication materials, including any new billing requirements\nthat must be in place to support the SSO; and\n\n19\nDCCEEW 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 14. Page 7\n• Updates required to the National Energy Retail Rules and ‘Model terms and conditions for standard\nretail contracts’20 to support the SSO design, such as those relating to the proposal that customers can\nrequest to be moved to a ‘fall back’ standing offer contract. In addition, it may be relevant to include a\n‘fair use’ policy in the model terms and conditions to help retailers manage the risks of excessive use of\nthe zero-charge usage window.\n\nENGIE notes that retailers have a significant pipeline of system change work in the lead-up to 1 July 2026 and limited resources to allocate to implementation work on the SSO. Most notably, retailers are dedicating significant resources in the first half of 2026 to the implementation of the Minister for Climate Change and\nEnergy’s substantial package of rule changes to help household access cheaper energy deals, increase support for people experiencing hardship, and deliver more protections for consumers.\n\n[Confidential information has been removed]\n\nENGIE recommends the SSO initially be trialled with a limited group to ensure it is designed effectively\n\nInstead of an obligation for retailers to make an SSO standing offer available to all residential customers with a smart meter from 1 July 2026, ENGIE proposes the Department initially implement the SSO through a limited trial available only to renters, apartment dwellers and low-income households in a single distribution region. This approach may minimise the risks to retailers arising from network tariff mismatches and the short implementation timeframe, while enabling the Department to monitor whether the SSO design is delivering the desired outcomes for renters, apartment dwellers and low-income households. As will be expanded on below, this alternative approach may:\n\n• Ensure that the SSO is designed for the customer cohorts it is intended to benefit, namely those that\nare unable access solar and battery storage;\n\n• Reduce the costs of facilitating an SSO, by requiring retailers to develop a targeted offer rather than\nimplementing significant system changes to support wider availability;\n\n• Enable distribution businesses to facilitate a harmonised tariff structure through tariff trials of network\ntariff structures with zero-charge usage periods;\n\n• Provide for evaluation and monitoring of the outcomes for households on the SSO relative to\nalternative offers, as well as the cost recovery for retailers when supplying the SSO.\n\nAn initial trial of the SSO would ensure any necessary adjustments to the SSO design can be made before the SSO is available more widely. This additional time could also be used for retailers to progress supporting\n\n20\nNational Energy Retail Rules version 47, Schedule 1\n\nPage 8\nsystem changes and updates to communications, as well as potentially progressing network tariff reforms that provide an SSO-equivalent network tariff structure.\n\nAccess to the SSO should be limited to households unable to access solar and battery storage\n\nAs noted in the consultation paper, the SSO is intended to extend the benefits of the energy transition to households without solar and batteries.21 Households that have invested in solar already have access to\n‘free’ electricity when their solar PV systems are generating electricity. Most households that install batteries will also have a solar system, including those that received discounts under the Australian\nGovernment’s ‘Cheaper Home Batteries Program’, which has eligibility linked to the premise having a new or existing solar PV system.22 For these households, the SSO’s primary value would be in ensuring they can access ‘free’ electricity during daytime hours regardless of whether their solar PV system is able to generate electricity on that day (such as, on a day with heavy cloud coverage). As noted earlier in this submission, retailers may face a significant cost exposure when supplying the SSO to these higher-income and savvy customer cohorts.\n\nThe SSO has the opportunity to have the most positive impact for households that are unable to access solar and batteries, such as those identified in the consultation paper – renters, apartment dwellers and low-income households.23 However, as noted earlier in this submission, these customer cohorts may be those least able or willing to change their energy consumption behaviour in response to a TOU pricing signal. An initial trial of the SSO could be helpful in ensuring the design of the SSO and associated communications can successfully meet its objectives of empowering these customer cohorts to actively manage their energy use and shift their consumption away from peak periods.\n\nTo ensure the SSO can be accessed by those households that may most benefit, the Department and the\nAER should also explicitly consider the availability of the SSO for customers in embedded networks. As the most common type of embedded networks are residential apartment buildings, many apartment dwellers and renters may not be able to benefit from the SSO if their embedded network operator is not obliged to make the SSO available.\n\nFacilitating a trial may be less resource-intensive than a wider implementation of the SSO\n\nENGIE notes that the costs and complexity of the SSO will be significantly higher if retailers are required to make the SSO available to customers in all jurisdictions. A trial that is limited to one distribution region may enable participating retailers to initially implement the SSO through work-arounds and limited system changes, rather than the significant system updates that would be required to support the wider obligation to make an SSO standing offer available to all residential customers with smart meters. ENGIE welcomes\n\n21\nDCCEEW 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 18.\n22\nDCCEEW, Cheaper Home Batteries Program, accessed at; https://www.dcceew.gov.au/energy/programs/cheaper-home-batteries\n23\nDCCEEW 2025, Solar Sharer Offer Consultation Paper 2025-26, November, pp. 18 & 21. Page 9\nopportunities to collaborate with the Department and industry on the project scope required to support a trial.\n\nIn terms of the distribution region that should be chosen for a trial of the SSO, ENGIE contends that the\nSAPN distribution region may be the most suitable choice. Compared to a region like New South Wales,\nSouth Australia only has one NEM DNSP and SAPN has network tariff structures that are more supportive than other DNSPs for an SSO-type offer.\n\nIn addition, South Australia has very high residential solar PV penetration, with almost half of dwellings having residential solar PV.24 South Australia also has the highest gap between minimum and maximum demand by time of day across the NEM, as demonstrated in the below chart from the AER’s ‘State of the\nEnergy Market’ report. For these reasons, South Australia may provide the most potential benefits for both households and the grid from an incentive to shift discretionary consumption to periods with high renewable generation.\n\nFigure 1: Average demand by time of day in 2024, by region25\n\n24\nAustralian Energy Market Operator 2024, South Australian Electricity Report, December, p. 17.\n25\nAustralian Energy Regulator 2025, State of the Energy Market 2025, August, p. 35 – AER and AEMO data sources. Page 10\nDistribution network tariff trials may provide a pathway to harmonised network and retail tariffs\n\nA trial of the SSO with restricted customer eligibility may enable DNSPs to also participate through a tariff trial of an SSO-equivalent network tariff with a zero-charge usage window. As previously noted, DNSP tariff trials have limited application and only permit the introduction of tariffs that do not recover more than 0.5 per cent of the DNSP’s annual revenue requirement.\n\nWithout a tariff trial, there may be limited prospects for harmonisation between network tariff structures and the SSO design in the short to medium term. Without a supporting network tariff structure, retailers would be supplying customers with ‘free’ energy in the zero-charge usage window while still incurring variable network costs for that consumption that would need to be recovered elsewhere.\n\nIdeally, following the outcomes of the SSO trial and supporting tariff trial, DNSPs across the NEM should be in a position to include SSO-equivalent network tariff codes in their TSS documents for AER approval in upcoming revenue determination periods.\n\nA trial allows evaluation and monitoring of outcomes for both consumers and retailers\n\nThe introduction of a trial would necessarily be accompanied by evaluation, monitoring and knowledge sharing. The AER’s process for DNSP tariff trials requires DNSPs’ to report on the results and learnings from the trials.26 The tariff trial learnings should provide useful information to the Department and the AER of the extent of consumer behavioural response to the SSO tariff structure.\n\nThe AER would also have an important role in monitoring and analysing outcomes for consumers and retailers from the SSO tariff design. In particular, the AER would be able to monitor whether consumers are receiving bill savings under the SSO relative to alternative tariff structures and whether retailers are able to recover their efficient costs of supplying SSO customers.\n\nLearnings from each of these sources would help inform the longer-term design of the SSO to ensure the policy meets the three key policy objectives27 before potentially being made available to a wider group of residential customers.\n\n26\nAustralian Energy Regulator, Tariff trials, accessed at; https://www.aer.gov.au/industry/registers/resources/reviews/tariff-trials\n27\nDCCEEW 2025, Solar Sharer Offer Consultation Paper 2025-26, November, p. 23. Page 11","size":381969,"redacted":[],"meta":{"name":"PUBLIC_20251121_ENGIE_submission_Solar_Sharer_Offer_Consultation_Paper_Redacted.4f904746.pdf","local_path":"files/W-iGQ1rk8sYJVBXDb5k2n2cm.pdf","transcribe_error":null,"transcribe_status":null},"config":{}}}}}