Guide for multifuel stations

This document provides guidance on multifuel stations. It was prepared to facilitate the integration of alternative fuels in existing fuelling stations and to facilitate the design, authorization and operation of multifuel stations.
This document compares the terms and definitions used in a selection of standards applicable to each fuel: electricity, hydrogen, compressed and liquefied natural gas, LPG, diesel and petrol.
It compares the requirements addressed in these standards for each fuel.
It describes the internal and external separation distances applied for different fuels.
It gives guidance on the design and operation of Emergency Shut Down systems and on combined activities.

SIST-V CEN/CLC Vodilo 38:2021

Vodilo za bencinske črpalke

General Information

Status
Published
Publication Date
14-Nov-2021
Technical Committee
Current Stage
6060 - National Implementation/Publication (Adopted Project)
Start Date
04-Nov-2021
Due Date
09-Jan-2022
Completion Date
15-Nov-2021

Buy Standard

Guide
V CEN/CLC Vodilo 38:2021 - BARVE
English language
76 pages
sale 10% off
Preview
sale 10% off
Preview
e-Library read for
1 day

Standards Content (Sample)

SLOVENSKI STANDARD
SIST-V CEN/CLC Vodilo 38:2021
01-december-2021
Vodilo za bencinske črpalke
Guide for multifuel stations
SIST-V CEN/CLC Vodilo 38:2021
Ta slovenski standard je istoveten z: CEN/CLC Guide 38:2021
ICS:
75.200 Oprema za skladiščenje Petroleum products and
nafte, naftnih proizvodov in natural gas handling
zemeljskega plina equipment
SIST-V CEN/CLC Vodilo 38:2021 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

---------------------- Page: 1 ----------------------
SIST-V CEN/CLC Vodilo 38:2021

---------------------- Page: 2 ----------------------
SIST-V CEN/CLC Vodilo 38:2021












CEN-CENELEC
GUIDE
38


















Guide for multifuel stations


Edition 1, 2021-10













CEN and CENELEC decided to adopt this new CEN-CENELEC Guide 38 through CEN Resolution
BT N 12651 and CENELEC Decision BT169/DG12327/DV.

---------------------- Page: 3 ----------------------
SIST-V CEN/CLC Vodilo 38:2021











European Committee for Standardization
European Committee for Electrotechnical Standardization
Rue de la Science 23

B–1040 Brussels – Belgium
Tel: +32 2 550 08 11
Fax: +32 2 550 08 19












www.cen.eu



www.cenelec.eu



www.cencenelec.eu

---------------------- Page: 4 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
Contents Page
European foreword .4
Introduction .5
1 Scope .6
2 Normative references .6
3 Terms and definitions .6
4 Safety of a multi energy station .8
4.1 General .8
4.2 Internal separation distances .8
4.2.1 General .8
4.2.2 Prescriptive separation distances .8
4.2.3 Concepts for separation distances. 10
4.3 Combined activities . 10
4.4 Process Shutdown and ESD functionality . 10
4.4.1 General philosophy . 10
4.4.2 ESD 3 . 11
4.4.3 Process shut down or stop button . 12
4.4.4 ESD 2 . 13
4.4.5 Functionality of an ESD system . 15
Annex A (informative) List of terms and definitions used in fuel station standards . 17
Annex B (informative) Requirements addressed in fuel station standards . 72
Bibliography . 76


3

---------------------- Page: 5 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
European foreword
CEN and CENELEC develop European Standards (EN) and other publications, including Technical
Specifications (TS), Technical Reports (TR) and Workshop Agreements (CWA). The European
Standardization System has made a significant contribution to the creation of a common European
market, embedded in a global economy, and in disseminating the knowledge incorporated in these
publications through its network of CEN and CENELEC (national) Members.
To accelerate the development of alternative fuels, CEN and CENELEC developed this Guide 38 to
facilitate the integration of alternative fuels at existing fuelling stations and to give guidance to design,
authorize and operate new multi fuel stations with different fuels in support of the Directive
2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of
alternative fuels infrastructure. Other EU legislations considered as relevant are listed in the
Bibliography: ATEX, PED, MID (other EU Directives or Regulations might apply).
4

---------------------- Page: 6 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
Introduction
The transport sector contributes to the Greenhouse Gas emissions, and it will also contribute to the
Energy Transition. In addition to improved efficiency and reduction in fuel consumption, the European
Commission is targeting the development of alternative fuels.
The Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the
deployment of alternative fuels infrastructure was published to facilitate the development of alternative
fuels and achieve interoperability throughout Europe. This Directive was requesting technical
specifications for recharging points, hydrogen refuelling points for motor vehicles and natural gas
refuelling points. These standards have been published by the relevant CEN and CENELEC Technical
Committees (CEN/TC 301, CLC/TC 69X, eMCG, CEN/TC 268, CEN/TC 326 and CEN/TC 408).
To facilitate the integration of alternative fuels in existing stations, CEN and CENELEC organized a
workshop in February 2019 with the relevant CEN and CENELEC Technical Committees (the TCs
already involved in Directive 2014/94/EU plus CEN/TC 286 and CEN/TC 393) and with the relevant
European Associations (Fuels Europe, Europe’s Independent Fuel Suppliers, Liquid Gas Europe, NGVA
Europe). The existing standards and regulations for each fuel were presented. Four topics were
identified as requiring guidance to facilitate the coexistence of different fuels:
— Emergency Shut Down procedure
— Common language – aligned terms
— Common approach of risk assessment
— Covered requirements in standards
The Working Group "Multifuel stations" was launched by the CEN-CLC Sector Forum Gas Infrastructure
(SFG-I) to draft CEN-CLC Guide 38. This Guide was submitted to the relevant CEN and CENELEC
Technical Committees (CEN-CLC/JTC 6, CEN/TC 301, CLC/TC 69X, eMCG, CEN/TC 268, CEN/TC 286,
CEN/TC 326, CEN/TC 393 and CEN/TC 408) and it was approved by the CEN and CENELEC BTs.
The intention of this document is to enable the relevant TCs to cover interaction with other fuels when
they revise their standards and improve alignment with other standards. It does not intend to cover all
the requirements to be applied in a multifuel station.
At a later stage, further items were identified that will require common agreement: labelling, ignition
sources, fire extinguishers, emergency response, time for emergency shutdown.
5

---------------------- Page: 7 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
1 Scope
This document provides guidance on multifuel stations. It was prepared to facilitate the integration of
alternative fuels in existing fuelling stations and to facilitate the design, authorization and operation of
multifuel stations.
This document compares the terms and definitions used in a selection of standards applicable to each
fuel: electricity, hydrogen, compressed and liquefied natural gas, LPG, diesel and petrol.
It compares the requirements addressed in these standards for each fuel.
It describes the internal and external separation distances applied for different fuels.
It gives guidance on the design and operation of Emergency Shut Down systems and on combined
activities.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
EN 13617-1:2012, Petrol filling stations - Part 1: Safety requirements for construction and performance of
metering pumps, dispensers and remote pumping units
EN 14678-1:2013, LPG equipment and accessories - Construction and performance of LPG equipment for
automotive filling stations - Part 1: Dispensers
EN 14678-2:2007+A1:2012, LPG equipment and accessories - Construction and performance of LPG
equipment for automotive filling stations - Part 2; Components other than dispensers, and installation
requirements
EN 14678-3:2013, LPG equipment and accessories - Construction and performance of LPG equipment for
automotive filling stations - Part 3: Refuelling installations at private and industrial premises
EN ISO 16923:2018, Natural gas fuelling stations — CNG stations for fuelling vehicles
EN ISO 16924:2018, Natural gas fuelling stations — LNG stations for fuelling vehicles
ISO 19880-1:2020, Gaseous hydrogen — Fuelling stations — Part 1: General requirements
IEC 61851-1:2019, Electric vehicle conductive charging system - Part 1 : general requirements
3 Terms and definitions
For the purpose of this document, the following terms and definitions apply.
The relevant CEN and CENELEC Technical Committees are encouraged to use these terms and
definitions in their standards.
The terms and definitions used for the different fuels in the standards listed in Clause 2 are compared in
Annex A.
6

---------------------- Page: 8 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
3.1
emergency shutdown system
ESD
system composed of sensors, logic solvers, and final control elements for the purpose of taking the
process, or specific equipment in the process, to a safe state when predetermined conditions are
violated
Note 1 to entry: The system is designed to isolate, de-energize, shutdown, or depressurize where appropriate,
equipment in a unit. Depressurization can be used for cryogenic liquids or parts of hydrogen systems.
3.2
fail-safe
capable to go to a predetermined safe state in the event of a specific malfunction
3.3
fuelling island
installation where single or multiple fuel dispensers, or refuelling points, for refuelling of road vehicles
are located
Note 1 to entry: Typically part of a facility containing multiple fuelling islands, with measures installed on each
island to protect the refuelling equipment from being impacted by vehicles (e.g. raised kerb and/or impact
protection barriers).
3.4
multi-fuel station
facility for the refuelling of road vehicles providing a selection of fuel types, and including facilities for
the supply of fuel to the facility, fuel storage and the fuel delivery equipment
Note 1 to entry: Multi-fuel stations may also include a charging, or recharging, infrastructure for battery electric
vehicles.
Note 2 to entry: Often referred to as fuelling station, refuelling station, filling station or service station.
3.5
process shutdown
system composed of sensors, logic solvers, and final control elements for the purpose of taking the part
of the process, or specific equipment in the process, to a safe state when predetermined conditions are
violated
3.6
separation distance
distance to acceptable risk level or minimum risk-informed distance between a hazard source and a
target (human, equipment or environment), which will mitigate the effect of a likely foreseeable
incident and prevent a minor incident from escalating into a larger incident
Note 1 to entry: The term "separation distance" may also be referred to as "safe distance", "safety distance" or
"setback distance".
[SOURCE: ISO 19880-1:2020, 3.70]
7

---------------------- Page: 9 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
4 Safety of a multi energy station
4.1 General
At a fuelling station, different (alternative) fuels including electric charging can be offered. For each fuel,
separate standards are available. However, there is no description of how the different fuels should
interact in case of an emergency. The goal of this guidance is to describe the measures that can prevent
a minor incident with one of the fuels at a multifuel station from escalating into a larger incident.
The regulations and standards for traditional fuels like petrol and diesel have existed for many years.
Today, alternative fuels such as LPG, CNG, LNG and hydrogen and electric charging are being
introduced. Several other fuels are under development, but as previously mentioned the focus of this
document is on commercially available alternative fuels. The safety procedures in case of an emergency
are written down separately in the standard for each individual fuel. This guidance will describe the
interaction between the fuels and technical installations at a multifuel station.
There are three main focus areas in the case of multifuel stations:
1) internal and external separation distances;
2) combined activities;
3) ESD action.

4.2 Internal separation distances
4.2.1 General
As mentioned, the standards for the individual fuels already exist (see Clause 2). Some standards
require separation distances, some give concepts to define these distances and for others the distances
are defined by national regulations and/or standards. The same internal distances as mentioned in the
separate fuel station standards are applicable for the technical installations of the other fuels at the
multi fuel station. National standards/codes of practice might give stronger requirements than those
given as examples below. When designing a multifuel station, as an alternative, a quantitative risk
assessment can be used to redefine the separation distances to achieve the same level of safety.
4.2.2 Prescriptive separation distances
4.2.2.1 Separation distances for Compressed Natural Gas
The distances mentioned in EN ISO 16923:2018 can be found in Table 1.
Table 1 — Separation distances for Compressed Natural Gas
Total site storage below 10 000 l
Hazard source Dispenser Storage cylinders and compressor
Buildings openings >3 m >3 m
Building walls (non-combustible) ≥0m >1 m
Facility perimeter >5 m >5 m (>10 m for storage > 10 000 l)
If a 2 h fire wall is located between CNG equipment and the property line, the separation distance may
be reduced to 1 m. The fire wall shall have a minimum height equal to 0,5 m greater than the maximum
height of the equipment and shall limit the hazardous zone from crossing the property line.
8

---------------------- Page: 10 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
4.2.2.2 Separation distances for Liquefied Natural Gas
The distances mentioned in EN ISO 16924:2018 can be found in Table 2.
Table 2 — Separation distances for Liquefied Natural Gas
Description Distance (m)
LNG storage towards vehicle fuelling 4
LNG storage towards onsite storage of other fuels 5
3
LNG storage (< 120 m ) towards site boundary 3
3
LNG storage (120 m3 to 300 m ) towards site boundary 6
3
LNG storage (> 300 m ) towards site boundary 10
On-site buildings to unloading point 10 m for ground
mounted pump
< 10 People
On-site buildings to unloading point 20 m for trailer
mounted pump
< 10 People
On-site buildings to unloading point 30 m
10 to 100 People
On-site buildings to unloading point 50 m
> 100 People
Off-site buildings to unloading point 10 m for ground
mounted pump
< 10 People
Off-site buildings to unloading point 20 m for trailer
mounted pump
< 10 People
Off-site buildings to unloading point 30 m
10 to 100 People
Off-site buildings to unloading point 50 m
> 100 People
LNG unloading point towards tank and buildings 6
LNG unloading point towards site boundary 3
4.2.2.3 Separation distances for hydrogen
The distances are not determined by ISO 19880-1:2020: no distances are mentioned in the standard.
9

---------------------- Page: 11 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
4.2.2.4 Separation distances for LPG
The distances are not determined by EN 14678: no distances are mentioned in the standard.
4.2.2.5 Separation distances for Petrol
The distances are not determined by EN 13617-1:2012: no distances are mentioned in the standard.
4.2.2.6 Separation distance for high power charging
Besides the traditional electrical installation standards in Europe no specific standard is currently
available to determine separation distances for high power charging stations. The distance of electrical
equipment for gaseous fuels is determined by the ATEX zones and by the hazardous area classification
of gaseous fuels (IEC 60079-10). In case the EV charging is located at a remote area of the fuelling
station such that it does not have any impact on the technical installation of the other fuels, it is not
necessary to combine the ESD functions.
4.2.3 Concepts for separation distances
The following concept was proposed for hydrogen refuelling stations by ISO 19880-1:2020: examples of
separation distances are determined by the heat flux. The heat flux is given in Table 3.
Table 3 — Heat flux related and related harm
Description Heat flux
2
(kW/m )
prevent domino effects 8
prevent effects on windows of buildings 5
prevent consequences (“irreversible effects threshold for…how long exposure” from 3
API 521)
prevent consequences (in API 521 KHK committee document) 1,26

4.3 Combined activities
Unloading of fuel at a fuelling station is a high risk activity. Unloading two different fuels, such as petrol
and LNG, at the same time will increase the risk level. It should be prevented to unload two fuels at the
same time at a multi fuel station except if the trailer is used as a storage at the station and appropriate
mitigation measures are taken.
In some cases, it can be done by combining the unloading points so that it is impossible to unload two
tanker trailers at the same time. Clear working instructions should be in place.

4.4 Process Shutdown and ESD functionality
4.4.1 General philosophy
Different aspects must be taken into consideration when ESD functionality is described. The basic idea
of the ESD system is that in case of any emergency the complete installation should shut down in fail
safe mode to minimize the consequences of an emergency and to prevent escalation of the incident. A
total shut down of the whole fuelling station is called an ESD 3.
10

---------------------- Page: 12 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
There are different ways of activating an ESD 3:
— manually by pressing an ESD button;
— automatically when a gas, flame or temperature detector is activated.
The general idea is that if a person presses the ESD button, the complete station should be shut down.
The reason that a person is pressing the ESD button is that the person noticed a dangerous situation.
Therefore, it is proposed to install one clearly marked central ESD button at a highly visible and easily
accessible location, for example at the shop or at each dispenser island. This central ESD button
connects all the ESD systems of the different fuels and charging systems. When that central ESD button
is pressed, all dispensing of fuels should shut down automatically including dispensers and EV chargers
and all technical installations should go into fail safe mode.
There should be no difference between an attended or unattended fuelling station. In case of an
attended fuelling station, an additional ESD button can be placed in the shop.
To prevent escalation of an incident caused by fire at a multi fuel dispenser island, there should be
flame detectors or high temperature (> 70 ̊C) detectors installed per dispenser island which activates
the ESD 3 system.
The reference documents can be found in the Bibliography ([1], [2], [3] and [4]).
4.4.2 ESD 3
All fuels dispensing and charging systems are disconnected when activated, all technical installations go
into fail safe mode.
It is activated by:
— a central ESD button and ESD buttons placed at the technical installation or other easily accessible
and highly visible location such as the shop;
— low /high temperature detection.
The ESD system should trigger a visual and audible alarm that is unique and immediately recognizable
by personnel on site.
Reset is only possible by trained technicians after inspection on site.
11

---------------------- Page: 13 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)

Figure 1 — ESD 3 activation by ESD button or flame/high temperature detection
In Figures 1 to 4, a few examples of technical installations are given. It is meant to show all technical
installation on a multi energy station such as the technical installations for petrol, diesel, LPG, CNG, LNG,
Hydrogen and High power charging.
In case of an incident at separate dispenser locations which cannot have an effect on each other or
cannot have an effect on the technical installations, the ESD system doesn’t need to be coupled and can
work independently of each other. This is often the case with EV charging. If the high-power charging
unit can have an effect (fire) on for example the storage of a CNG system, then the ESD systems should
be coupled.
4.4.3 Process shut down or stop button
In the current situation, all alternative fuels like CNG, LNG, Hydrogen and EV have their own ESD button
at each dispenser. It often happens that untrained users are wrongly using the ESD button when they
are experiencing a (non-hazardous) problem. This causes a lot of unnecessary ESD actions. For
operational purposes, the dispensers of the alternative fuels can be equipped with a stop button instead
of an ESD button. The stop button will cause a process shut down of fuelling (or charging) of the specific
fuel dispenser at the dispenser island when pressed. This can be the case when the user makes an
operational error and wants to stop the fuelling (charging) process.
Stop button:
• Activated by stop button on dispenser
• Should isolate the single dispenser and should automatically be disconnected from the fuel supply
• Remote reset possible
• If dead man button is not pressed at the right time during LNG unloading
• If dead man button is not pressed at the right time during LNG dispensing to customer
12

---------------------- Page: 14 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)

Figure 2 — Process shutdown: stop button activated at dispenser
4.4.4 ESD 2
All technical systems of alternative fuels are equipped with safeguards which will cause a process shut
down when activated. There are two situations which can cause a process shutdown: a) safeguard
activated in technical installation and b) safeguard activated at the dispenser island.
ESD 2 action
a) In the case of a process alarm in the installation such as a high temperature in the technical
installation, it is not necessary to shut down the whole fuelling station, but only the specific fuel system.
• Activated by safeguard in technical installation
• Complete process shut down
• Whole single fuel system should be shut down and will go into fail safe mode, if safeguard is
activated in the technical installation
• The ESD system should trigger an automated alarm to the (remote)control room
• Reset only after visual inspection at site
13

---------------------- Page: 15 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)

Figure 3 — ESD 2 activated by safeguard in technical installation
b) In the case of the activation of a safeguard at the dispenser island caused by for example gas
detection, the other fuels at the dispenser island should be shut down as well.
ESD2:
• Activated by safeguard at dispenser island
• Complete process shut down
• Whole single fuel system will be shut down and go into fail safe mode, if safeguard is activated at
the dispenser island installation
• Isolate the other fuels at the same dispenser island.
• The ESD system should trigger a visual and audible alarm that is unique and immediately
recognizable by personnel on site
• Reset only after visual inspection at site
14

---------------------- Page: 16 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)

Figure 4 — ESD 2 activated by safeguard at dispenser island

4.4.5 Functionality of an ESD system
Below gives a description of which systems should be shut down according to the current European
Standards. The actions of the ESD system during normal operation differs from fuel to fuel:
• Petrol/Diesel: not very specific, reference is made to EN ISO 13849-1. A safety-related stop function
(e.g. initiated by a safeguard) should, as soon as necessary after actuation, put the machine in a safe
state. Such a stop should have priority over a stop for operational reasons. When a group of machines
are working together in a coordinated manner, provision should be made for signalling the supervisory
control and/or the other machines that such a stop condition exists.
• LPG: when an ESD push button is activated, the electric system of the LPG part of the station's
facilities, excluding the emergency lighting if present, should be switched off, and all actuators should
close the valves within 15 s; ESD system should completely isolate the delivery and dispensing pipe-
work from the storage pressure vessel.
• CNG: a) The compressor and dispensers should be shut down, and the outlets of any buffer storage
should be isolated by the operation of fail-safe automatic valves. The isolation should be made as close
to the storage as possible. b) The power supply should be isolated with the exception of power for
safety control and mechanical ventilation systems. c) The gas supply should be shut off at the fuelling
station gas supply inlet, compressor inlet, buffer storage outlet and dispenser.
• H2: the standard is not very specific: it should, while the process steps are similar to CNG, shut
down the gas supply (by e.g. tank trailer) or stop the local H2 production (electrolyser or steam
reformer), stop the compressor, close the output of the H2 storage and close the supply at the
dispenser.
• LNG: The ESD system should switch the plant valves and other equipment into a safe state, as a
minimum, closing the LNG storage tank liquid outlet valves; shut down the LNG pump of the fuelling
station; closing the inlet/outlet valve of each dispenser.
15

---------------------- Page: 17 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
• HPC: An HPC system is also equipped with ESD system, which is connected to shut off the power in
case of an incident. ESD buttons are placed both on the dispenser and on the technical installation.
Other emergency shutdown functions may include:
— venting of any remaining gas in the dispensing system to an appropriate location;
— removal of power to electrical components in the vicinity of the dispenser that are not suitable for
classified areas.
16

---------------------- Page: 18 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
Annex A
(informative)

List of terms and definitions used in fuel station standards
The terms and definitions used in the 8 standards listed in Clause 2 have been compared:
— 346 terms have been recorded with 383 definitions. 316 terms are used by only one fuel.
— 2 terms are used by four different fuels: "dispenser" and "hazardous area".
— 3 terms are used by three different fuels: "breakaway coupling/device", "fuelling/filling station"
and "maximum allowable (working) pressure".
— 25 terms are used by two different fuels.
These can be found in Table A.1.

17

---------------------- Page: 19 ----------------------
SIST-V CEN/CLC Vodilo 38:2021
CEN-CLC Guide 38:2021 (E)
Table A.1 — Terms and definitions used in fuel station standards
Term Natural gas LPG Hydrogen Diesel – Gasoline Electricity
EN ISO 16923:2018 EN 14678-1:2013 ISO 19880-1:2020 (81 EN 13617-1:2012 IEC 61851-1:2019
(56 def) (17 def) def) (42 def) (71 def)
Natural gas fuelling Petrol filling s
...

Questions, Comments and Discussion

Ask us and Technical Secretary will try to provide an answer. You can facilitate discussion about the standard in here.