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Report on the Technical Feasibility of Integrating an Annual Average 2% Renewable Diesel in the Canadian Distillate Pool by 2011

3  Technology/End-User Application Readiness

3.1  Key Factors
3.2  Main Findings
3.3  Analysis

For the purposes of this report, technology/end-user application readiness means that methods to mitigate any negative impacts on engines and equipment related to renewable diesel use in Canada are identified. An assessment to confirm technology/end-user application readiness includes identified potential negative impacts, the end-users and locations where these impacts occur and the magnitude or severity of these impacts. Note that the mitigation measures will address the action taken to overcome the negative impact, the end-user responsible for implementing the measures and the anticipated duration of each measure. Where available, the associated costs for each measure will be noted. Note: it may not be possible in all cases to identify and apply mitigation measures.

3.1  Key Factors

The end-user is the last link in the renewable diesel supply chain and technology/end-user application readiness looks at their ability to use a renewable diesel blended fuel in their conventional diesel operations. A literature review and discussion with stakeholders identified the following factors which were raised as areas of concern where the properties of biodiesel could have an effect on the ability of the user to seamlessly use renewable diesel blended fuel in their operations:

  • End-user Operability
  • Solvent Effect
  • Materials Compatibility
  • Effect on Diesel Exhaust After-Treatment Equipment
3.1.1  End-User Operability

End-user operability is difficult to precisely define as it can have a different meaning for each end-user depending on many factors, including the user’s familiarity with renewable diesel. Generally, it could be expected that end-users would anticipate a B2 to B5 blend to have performance characteristics comparable to petroleum diesel. End-user operability is generally related to overall performance and loss of service. Some operability challenges, which users might experience, could be fuel gelling and filter plugging leading to vehicles stalling or not starting.

3.1.2  Solvent (or Cleansing) Effect

With continued use of petroleum diesel, certain materials can accumulate and form deposits which permanently stick to the bottom of storage and vehicle fuel tanks. Biodiesel has a solvent effect33 that will re-dissolve the deposits into the fuel blends and can carry them into the filter. The use of biodiesel blends in vehicles and storage tanks that have previously used only petroleum diesel can lead to the requirement for a “cleansing period” where more frequent filter changes will be required. The extent of this requirement will depend on the length of time the diesel deposits have had to form, as well as on the level of biodiesel blend.

3.1.3  Materials Compatibility

B100 is not compatible with some metals, plastics and rubbers. It may soften and degrade certain types of rubber compounds used for hoses and gaskets (buna-N, nitrile, natural rubber) and may cause them to leak. B100 will degrade and form high sediment levels if in contact for long periods with copper or copper-containing metals (brass, bronze) or with lead, tin or zinc (galvanized surfaces). These high sediment levels may clog filters. B100 may also permeate some common plastics (polyethylene, polypropylene) over time.34

Potential issues with the use of biodiesel in furnace equipment have been described to be: altered injection systems and nozzles due to material incompatibility, different flame luminosity leading to the incapacity of sensors to detect the flame, and increased stack temperature.

The impact of biodiesel’s incompatibility with certain materials decreases with decreasing blend levels.

3.1.4  Effects on Diesel Exhaust After-Treatment Equipment

There could be interactions between the products of biodiesel combustion and the diesel exhaust after-treatment systems installed in 2010 model-year on-road vehicles to meet more stringent requirements for reduced tailpipe emissions. Traces of inorganic compounds contained in biodiesel may have a potentially negative impact on after-treatment devices, decreasing their efficiency and lifetime. The quantitative impact of biodiesel on these devices has yet to be fully determined, but as ASTM on-road diesel standards allow up to 5% biodiesel in regular diesel, it is expected that engine manufacturers will remain on top of this issue to ensure their products perform satisfactorily with the fuels available on the market. The NRDDI is relying on work accomplished by NREL to determine the key considerations with regard to this issue.

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3.2  Main Findings

Numerous projects have been carried out in Canada and the United States to evaluate renewable diesel in specific applications of which several are listed in Exhibit 2. In addition, NRDDI worked with numerous end-users to demonstrate and evaluate renewable diesel blends in their Canadian operations (see Exhibit 1). The key findings are divided into the following end-user categories and presented below:

  • On-road: trucking and industrial fleets, urban transit
  • Off-road: construction, agriculture, marine, rail/locomotive, forestry, mining
  • Stationary: space-heating furnaces, gensets
3.2.1  On-Road: Trucking and Industrial Fleets

Alberta Renewable Diesel Demonstration35

Application/Conditions Results
  • 59 vehicles (trucking and bus fleets) used FAME and HDRD
  • 16 control vehicles running on ULSD
  • B2 in winter and B5 in shoulder/summer seasons
  • All fuels were acquired and maintained to meet quality specifications
  • Model-years 2002 – 2008
  • Lowest temperature tested was
    -33 °C versus -44 °C originally expected
  • Confirmed operability of 2% renewable diesel/ULSD blends in winter in regards to vehicle performance under the conditions tested
  • No meaningful difference in fuel economy among biodiesel blends, HDRD blends and diesel fuel

British Columbia (BC) Trucking Association36

Application/Conditions Results
  • A 2009 survey
  • Out of 29 valid responses, a total of 21 companies used biodiesel in 1,762 vehicles
  • B5 used in 1,054 vehicles
  • B20 or higher in 680 vehicles
  • Blend unreported for eight vehicles
  • 13 fleets (62 %) experienced some type of operability issues.
  • The most commonly reported problem was fuel filter plugging. Of the companies that reported fuel filter plugging, one used B5, two used B20, two used B20+, and one was unsure of the blend level.
  • One company that reported other operability problems (fuel injectors) used B20.
  • Companies that reported fuel gelling (n=3) were all using B20 in winter. One indicated fuel gelling occurred at -5°C (wind chill
    -18°C). This company, as well as another that reported gelling, primarily operated on biodiesel in the South region. The third primarily operated on biodiesel in Northern BC.
  • One company indicated that the issue could not be resolved and that use of B20 had to be discontinued during the winter (switched to B5).

NRDDI – Manitoba Hydro Project: Fleets37

Application/Conditions Results
  • Manitoba Hydro has been running biodiesel at one of its fleet sites in Winnipeg since the fall of 2006.
  • The Manitoba Hydro fleets used B20 in the summer, B10 in the fall, B5 in the winter, and B15 late spring/summer.
  • Vehicles parked in partially heated garage.
  • There have been no recorded operational or dispenser plugging issues as a result of biodiesel use.
  • This applies to both the period of the NRDDI project from August 2009 to April 2010 and the prior two years of biodiesel use.
3.2.2  On-Road: Urban Transit

BioBus – Montreal Project38

Application/Conditions Results
  • Bus operability tests used B5 and B20 biodiesel blends
  • 155 buses
  • Overnight temperatures dropped to -20°C to -30°C during three cold spells
  • Vehicles were either parked indoors at night or were kept idling when outside for long periods of time. Therefore, the fuel remained relatively warm.
  • No incident compromising continuity of service was experienced.
  • No bus-related mechanical problems, notably to the fuel injection system, nor any degradation of elastomer components in contact with the fuel.
  • No variation in fuel consumption can be substantiated from the data.
  • The cleansing period was longer than foreseen for buses with the finest (10-µm) filters, longer still because B5 was used for three months before cutting over to B20.
  • Sporadic filter plugging incidents occurred that were caused by the finest (10-µm) filters located farthest from sources of heat in the engine compartment of buses. The project report concluded that these incidents had no real impact on operability and resulted in no significant unforeseen costs.
  • It was discovered that temperature increases in the fuel system, due to fuel recirculation, made it possible to use a fuel with a cloud point higher than the ambient temperature. The tendency for fuel to be heated to up to 30°C above the ambient temperature (including in buses with electronic fuel injection) was confirmed by sampling tank temperatures for the various types of buses on a cold March 2002 morning following an overnight low of -20°C.

BioBus – Saskatoon Project39

Application/Conditions Results
  • Two older 6V-92 and two newer D-50 powered buses were selected for city route testing over a two-year period (model years were not reported).
  • Fuels were alternated between B5 and seasonal low sulphur diesel.
  • Controlled highway tests were performed on a fifth bus in summer to measure fuel economy and wear in highway driving, using petroleum fuel, as well as B0.1, B2 and B5.
  • Tested to -44°C
  • The addition of the CME improved lubricity by decreasing wear areas and coefficients of friction for all seasons. The lubricity of the B5 had a good influence on engine wear rates and fuel economy with 7.8% to 23.4% lower engine wear and 2.7% to 4.3% better fuel economy in city driving with the same intact engines.
  • Ferrographic, magnetic and oil filter analysis of larger wear particles indicated only small differences between the various fuels tested.
  • The fuel injectors remained clean for all fuels and no fuel related problems were encountered.
  • The application of B5 conserved the acid neutralization capability of the used motor oil as indicated by its higher Total Base Numbers.
  • The oil viscosity remained acceptable whether or not biodiesel was being burned.
3.2.3  Off-Road: Construction

NRDDI – FPInnovations Project: Construction40

Application/Conditions Results
  • Equipment worked 8 hours/day
  • B10 – this location experiences milder temperatures year-round
  • Fuel quality was demonstrated to have been maintained
  • The 13,000 hours of operation were reported to be problem free.
  • In-tank blending was found to have significant variability in the blend ratio, and while this did not adversely impact operations, it is an area of concern.
  • This study provides evidence that biodiesel blends in the B2 to B10 blend ratio can be used with little to no preparation on the part of the end-user in the highway construction sector.
  • No changes to current fuelling practices with regard to delivery and short-term storage were needed, including remote locations and areas.
  • Equipment that is well maintained with oil and fuel filters replaced at the OEM specified interval should encounter no issues.
3.2.4  Off-Road: Agriculture

NRDDI – Saskatchewan Research Council Project41

Application/Conditions Results
  • B3 (winter) and B10 (fall/spring) CME blends were tested
  • August 2009 to May 2010
  • Fuel in half the farming equipment that was stored over winter had stability enhancers added to see how the fuel degraded under each scenario; error resulted in 20 times the amount of additives being added to the B5
  • Tanks not cleaned or prepared for biodiesel blends
  • Unheated sheds for equipment; unsheltered and unheated fuel storage tanks over all seasons
  • Farm equipment; 12,000 litres of biodiesel.
  • This demo did not make any changes to producer practices related to bulk tank storage throughout the monitoring period.
  • Fuel quality was demonstrated to have been maintained.
  • Producers indicated (via conversations and survey) that no equipment operational problems were experienced in the project, and no changes with respect to operating on diesel were noted.
  • The adoption of low-level blends into this demonstration did not require changes on the part of agricultural producers in relation to on-farm bulk fuel storage practices.
  • During winter off-season storage of equipment, no substantive benefits were identified related to filling equipment fuel tanks to minimize fuel contact with air during storage.
  • Although oxidative stability enhancers demonstrated improvements to the stability of the CME blended fuel used in this demonstration, the quality of non-treated fuel in farm equipment remained sufficient over the winter storage period.
3.2.5  Off-Road: Marine

BC Ferries Project42

Application/Conditions Results
  • In September 2009, BC Ferries ran B5 in their Queen Alberni vessel for six weeks.
  • No biocides were used in the project.
  • Water accumulation in the storage tanks was monitored.
  • Fuel samples were taken and checked for microbes and water content. There was no microbe count in the fuel samples.
  • Where a substantial amount of free water was found in the fuel samples, some vessels decided to more frequently drain watery fuel from the tanks as a preventative measure; others did not change their usual practices.
  • The fleet has not experienced problems with the solvent effect of biodiesel or increased microbial growth.
Note: As of April 2010, 31 out of 36 ferries are using B5. BC Ferries worked with its fuel supplier for over a year before implementing the new product in order to ensure that the safety and reliability of the vessels would not be compromised.43

BioMer Montreal Project44

Application/Conditions Results
  • Examined the use of B100 as a petrodiesel replacement; evaluated its economic viability and advantages; and measured various environmental aspects
  • Primarily cooking oil-based B100, but also B5, B10 and B20 blends
  • 12 tourist cruise boats
  • May to October 2004
  • Minor operational incidents due to filter plugging problems that were deemed predictable.
  • Engine performance was not diminished; however, a 3% increase in fuel consumption was noted for B100.

Washington State Ferries Biodiesel Project45

Application/Conditions Results
  • B5 and B20 blends in three marine vessels in the Pacific Northwest area of the United States
  • Occasional incidents where ferry engineers reported that there were elevated levels of sludge found in the fuel purifiers. Excessive microbial growth was suspected to have caused the problem.
  • Biocides were used effectively to mitigate the problem.
3.2.6  Off-Road: Rail/Locomotives

NRDDI – Canadian Pacific Railways Project46

Application/Conditions Results
  • Five-month test cycle (November 2009-March 2010)
  • B5 (SME and ULSD)
  • Between Calgary and Edmonton
  • Four GE AC4400CW diesel-electric locomotives with FDL-16 engines on a continuous basis
  • Lowest temperature: -40°C
  • The company conducted detailed mechanical examinations of the locomotives before and after the tests.
  • Locomotives were fuelled directly from the fuel delivery vehicle which is the standard practice. (There was no intermediate storage.)
  • No operability issues were encountered and no loss-of-service events were noted.
  • Engine inspections demonstrated no negative mechanical effects from the use of B5
  • Successfully demonstrated the viability of B5 use in cold weather freight service
3.2.7  Off-Road: Forestry

NRDDI – FPInnovations Project: Forestry47

Application/Conditions Results
  • Three sites: a sawmill in Prince George and a logging site in Merritt, BC; and a logging site in Saint-Ludger-de-Milot, Quebec
  • Six months at Prince George; three weeks at Saint-Ludger-de-Milot and two weeks at Merritt.
  • 45 machines
  • Tested in environments as cold as -31.4°C; temperatures below
    -20°C for three to four days on three occasions
  • At Prince George most of the machinery was stored in a heated garage when not operating.
  • Sawmill machine shifts ranged from 10 to 17 hours, and the logging sites worked 11 hours/day at Merritt and 20 hours/day at Saint-Ludger-de-Milot. Monthly machine hours at the sawmill ranged as high as 350 hours for one machine to a low of 8 hours for machines that are used on a backup basis.
  • Preventative measures prior to biodiesel use were employed at only one site (tank cleaning and the installation of a vent-dryer as well as a filter on the dispensing pump). In other situations, where smaller storage tanks were used, only standard filters were fitted to the dispensing pumps, and at one site no filters were fitted to the dispensing pumps.
  • Machine operators could tell no difference in machine power and were positive on the project as a whole. The monitoring devices also showed the ratio of motion time to engine runtime, also referred to as utilization ratio, and from this data, it was readily apparent that productivity of machinery running biodiesel was the same as machinery running ULSD.
  • Blends in the B2 to B5 range can be used with little to no preparation on the part of the end-user forest operation sector.
3.2.8  Off-Road: Mining

Evaluation of Biodiesel Fuel and Oxidation Catalyst in an Underground Metal Mine48

Application/Conditions Results
  • A multilateral study in an Ontario mine in 1997
  • Evaluated the potential to reduce diesel particulate matter and other diesel exhaust emissions by using biodiesel.
  • The blend consisted of 58% (by mass) SME biodiesel and a low sulphur seasonal diesel.
  • All of the polluting species including particulate matter were at lower or equal levels compared to the same equipment operating with seasonal diesel.
3.2.9  Stationary: Space-Heating Furnaces

NRDDI – Imperial Oil Project: Bio Furnace Fuel Test49

Application/Conditions Results
  • Aimed to evaluate the long term performance of late-model furnaces using bio-furnace fuel.
  • Blends of B5, B10 and B20 were tested in three identical late-model high efficiency furnaces for periods of 3x40 day cycles to simulate spring/fall, moderate severity and winter cold snap operations.
  • As there is currently no Canadian standard in place for bio-furnace fuel oil, fuel was tested against the Heating Fuel Oil Standard CAN/CGSM-3.2. All bio-furnace fuels used in the tests met this standard.
  • Furnace operation and performance were evaluated by weekly monitoring of furnace operating parameters as well as a furnace system inspection after each 40-day test cycle.
  • Inspections of the furnace system after each test cycle included inspections of the filters, burners, pumps, burner nozzles and heat exchangers. Furnace inspection and tuning and maintenance were performed by an independent, qualified furnace technician who was unaware of the fuel compositions being tested.
  • Negligible impact on furnace operation and performance with furnace fuel up to B10.
  • Bio-furnace fuel should not exceed B10 in order to be compatible with existing seals in the fuel pump.
  • Deposits were observed in the drain lines of two of the three fuel tanks after the test carried out over the coldest period; however this did not affect the performance and operability as defined by the evaluation criteria.
3.2.10  Stationary: Gensets

NRDDI – Manitoba Hydro Project: Gensets50

Application/Conditions Results
  • B5 in gensets for power generation
  • Remote northern Canadian location where fuel is delivered on ice-roads in January and must remain fit-for-purpose until the next January.
  • Before entering the gensets, the fuel stored outside of the powerhouse was pumped into two indoor parallel 750L tanks, where the diesel was warmed up for 12 to 18 hours, depending on the load demand. In this particular case, the normal diesel fuel is handled in the same manner.
  • Operated without any issues, without requiring additional maintenance.

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3.3  Analysis

3.3.1  End-User Operability

On-Road Sector

No additional on-road demonstrations were carried out under NRDDI, as industry stakeholders had just completed the ARDD and saw no further need for another real-world demonstration in advance of the intended regulation. The ARDD confirmed operability of B2 in winter and B5 in shoulder/summer seasons under the conditions tested, without any significant loss-of-service incidents.

The vast majority of documented engine impacts and operability problems reported have been related to B20 and above. In general, the most notable outcome was occasional filter plugging.

Most on-road stakeholders confirm that blends of up to B5 should not cause major issues. The certainty with which this statement can be made increases for newer truck models and decreases for older ones. A tentative definition of “newer” as it relates to biodiesel use would appear to be model year 2002 and newer.51

Off-Road Sector

During the NRDDI demonstrations projects, operation on B5 was not shown to cause any significant loss-of-service incidents. Vehicle age varied from model years 1967 to 2010. Most of the vehicles were of model year 1994 or newer.

Measures were taken to account for the unique properties of biodiesel. These included tank cleaning, fuelling directly to the vehicle (no storage of the fuel), ensuring the cloud point of the diesel fuel was appropriate for the location/temperature, and parking the vehicles indoors.

Stationary

Results indicated negligible impact on furnace operation and performance with fuel up to B10.

The use of B5 in gensets for power generation in remote northern Canadian locations has been demonstrated in both warm and cold seasons without any issues or requiring additional maintenance.52

Fuel Economy

Although not an aspect of technical feasibility, many projects reported on fuel consumption with varying results. As the blend level is lowered, differences in energy content become proportionally less significant; blends of B5 or lower cause no easily noticeable differences in fuel consumption in comparison to Type B diesel.53

3.3.2  Solvent Effect

The biodiesel solvent or cleansing effect is most often manifested in plugged filters and generally B100 exhibits the most pronounced effects.

The early stage of switching from petroleum diesel to biodiesel blends has been demonstrated to be the most vital phase during which filter plugging related to the biodiesel solvent effect can occur. The risk and time of onset of filter clogging increases with biodiesel blend, and naturally depends on time allowed for build-up of deposits during petroleum diesel usage. Incidents were deemed as predictable and not having an impact on operations or leading to significant costs except new filters and the related labour costs.

In its research, NREL found the cleansing effect should not be an issue with B5 and lower blends. Most users did not clean their tanks before B20 use, although it is still wise to keep some extra filters on hand and monitor potential filter clogging a little more closely. The cleansing effect of biodiesel at a B20 level is sufficiently diluted that most problems are insignificant, but the fuel filter could plug quickly when the fuel is first used.

As this is a known and predictable problem, the risk of filter plugging can be mitigated by providing adequate training, more frequent filter changes, and the availability of sufficient filter supplies.

3.3.3  Materials Compatibility

The propensity for biodiesel to degrade certain materials is most pronounced for B100. This tendency has been found to decrease as the blend level decreases. Issues regarding higher-level blends are more likely to arise for storage, transportation and dispensing equipment for B100 prior to final blending to B5 (or lower).

An increasing number of OEMs are endorsing use of up to B5 in their equipment. As such, NRDDI projects did not generally examine long term effects, like wear, materials compatibility or longevity and did not find any issues which could be specifically attributed to it. However, the NRDDI Imperial Oil study suggests, in space-heating furnace applications, biofuel should not exceed B10 in order to be compatible with existing seals in fuel pumps for late-model equipment. In the case of NRDDI CP Rail’s locomotive demonstration, engine inspections demonstrated no negative mechanical effects from the use of B5.

In the BioBus Montreal project, biodiesel caused neither bus-related mechanical problems, notably to the fuel injection system, nor any degradation of elastomer components in contact with the fuel. In the BioBus Saskatoon project, ferrographic, magnetic and oil filter analysis of larger wear particles indicated only small differences between the various fuels tested. The fuel injectors remained clean for all fuels and no fuel related problems were encountered, even at -44°C.

NREL has found there have been no significant material compatibility issues with B20 (unless the B20 has been oxidized). NREL found B20 or lower blends minimize most issues associated with materials compatibility. This conclusion provides even more confidence in the minimal effects which can be expected with B5.

Like the solvent effect, materials compatibility is a known and predictable issue with biodiesel. Effects can be mitigated by replacing incompatible materials exposed to higher-level blends.

3.3.4  Effect on Diesel Exhaust After-Treatment Equipment

The evaluation of engine exhaust emissions requires specialized equipment and testing procedures. NREL is conducting extensive work on biodiesel’s impact on: the performance of selective catalytic reduction systems; emissions and durability of light and heavy duty vehicles operating with advance emission controls; and after-treatment durability. This work has focused on B20 blends and recommended practices arising from this work will provide further guidance for use of B5 blends in Canada. Therefore, special measures may not be needed for blends of B5 and lower.

In any case, the Engine Manufacturers’ Association (EMA) has stated “an average annual 2% renewable content in diesel fuel is technically feasible for existing heavy-duty engines and anticipated 2010 heavy-duty engines in Canada” (see Market Acceptance for the full statement). As ASTM on-road diesel standards allow up to 5% biodiesel in regular diesel, it is expected that engine manufacturers will remain on top of this issue to ensure their products perform satisfactorily with the fuels available on the market.

Given NREL’s work and the EMA statement, the examination of effects of biodiesel on exhaust after-treatment systems was not an element of the NRDDI projects.

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33 Assessment of the Biodiesel Distribution Infrastructure in Canada, 2007.

34 National Renewable Energy Laboratory, “Biodiesel Handling and Use Guide” Fourth Edition, December 2008

35 Alberta Renewable Diesel Demonstration, Final Report, February 2009.

36 BC Trucking Association, “Biodiesel Operability Survey”, 2009.

37 Manitoba Hydro “Long Term Storage and Use of Biodiesel in Fleets”, Final Report, June 2010.

38 BioBus – Montreal, “Biodiesel Demonstration and Assessment with the Société de Transport du Montréal (STM), Final Report , May 2003

39 Bio-Bus Saskatoon Phase II, “Final Research Report”, March 2006

40 FPInnovations, “Demonstration of the Potential Use of Biodiesel for Off-Road Machinery in Canadian Highway Construction and Forest Operations”. Final Report, June 2010.

41 Saskatchewan Research Council, “Off Road Biodiesel Demonstration Agricultural Sector”, Interim report, May 2010.

42 Natural Resources Canada, Meeting minutes from discussion with BC Ferries, April 2010.

43 BC Ferries Press Release, April 21, 2010.

44 BioMer, “Biodiesel Demonstration and Assessment for Tour Boats in the Old Port of Montreal and Lachine Canal National Historic Site”, Final Report, May 2005.

45 Washington State Ferry Biodiesel Research & Demonstration Project, Final Report, April 2009

46 Canadian Pacific Railway, “Biodiesel Demonstration Final Report”, June 2010

47 FPInnovations, “Demonstration of the Potential Use of Biodiesel for Off-Road Machinery in Canadian Highway Construction and Forest Operations”. Final Report, June 2010.

48 University of Minnesota, NIOSH, CANMET, ORTECH, Michigan Technological University and Inco, “Evaluation of Biodiesel Fuel and Oxidation Catalyst in an Underground Metal Mine”, September 1998.

49 Imperial Oil, “Bio Furnace Fuel Test”, Final Report, November 2009

50 Manitoba Hydro, “Demonstration of the Use of Biodiesel in Electric Generators in Remote Canadian Locations and Long Term Storage in Gensets”, Final Report, June 2010

51 British Columbia Trucking Association, “Biodiesel Operability” 2009

52 Manitoba Hydro, “Demonstration of the Use of Biodiesel in Electric Generators in Remote Canadian Locations and Long Term Storage in Gensets”, Final Report, June 2010.

53 National Renewable Energy Laboratory, “Biodiesel Handling and Use Guide” Fourth Edition, December 2008.