Californias Advanced Clean Cars Midterm Review Appendix G: Plug-in .

1y ago
15 Views
2 Downloads
3.48 MB
59 Pages
Last View : 2m ago
Last Download : 3m ago
Upload by : Axel Lin
Transcription

CaliforniasAdvanced Clean CarsMidterm ReviewAppendix G:Plug-in Electric Vehicle In-Use andCharging Data AnalysisJanuary 18, 2017

TABLE OF CONTENTSI. Introduction . 1II. Data Overview . 1II.A. Description of Data from Manufacturers . 2II.A.1. BMW . 2II.A.2. FORD . 3II.A.3. GENERAL MOTORS . 4II.A.4. HONDA . 6II.A.5. NISSAN . 7II.A.6. TESLA . 8II.A.7. TOYOTA . 8II.B. Summary Tables of Manufacturer-Provided Data . 9III. Analysis Methods for OEM Data Provided .10III.A. Calculation methods .10III.B. Data output format .12III.C. Discussion of uncertainties in results due to data issues .13IV. Trip Results .14IV.A. Annual means for each vehicle model .14IV.B. Annual Percent VMT, eVMT, zVMT, and e-trips.15IV.C. Average monthly plots for percent eVMT and zVMT, and e-trips for PHEVs .20IV.D. Analysis of factors affecting eVMT .25V. Charge Results .28V.A. Data provided .28V.B. Charging capability .28V.B.1. Nissan Plots .29V.B.2. Ford Plots .34V.B.3. Honda Plots.36V.B.4. General Motors Plots .38VI. Analysis of activity relevant to understanding criteria pollutant emission benefits .39VII. Literature Review .42VII.A. Simulated eVMT based on non-PEV household travel data .42VII.B. Empirical data from PEV loaners .43VII.C. Surveys of PEV households .44G - ii

VII.D. Empirical data from PEV households and fleets .47VIII. Summary .51IX. References .53LIST OF FIGURESFigure 1 - Annualized Mean VMT, eVMT and zVMT results by vehicle type .16Figure 2 - Annual Mileage by Vehicle Type per Model Year for PHEVs for US and CA vehicles.17Figure 3 - Annual Mileage by Vehicle Type per Model Year for BEVs for US and CA vehicles.18Figure 4 - Nissan Leaf Initial Year Annual Miles by Model Year and Lease Terms .20Figure 5 - Average Monthly %eVMT, %zVMT & %e-Trips for Ford C-Max Vehicles - All Trips .21Figure 6 - Average Monthly %eVMT, %zVMT & %e-Trips for Ford C-Max Vehicles - CA Trips .21Figure 7 - Average Monthly %eVMT, %zVMT & %e-Trips for Ford Fusion Vehicles - All Trips.22Figure 8 - Average Monthly %eVMT, %zVMT & %e-Trips for Ford Fusion Vehicles - CA Trips.22Figure 9 - Average Monthly %eVMT, %zVMT & %e-Trips for GM Volt Vehicles - All Trips .23Figure 10 - Average Monthly %eVMT, %zVMT & %e-Trips for GM Volt Vehicles – CA Trips .23Figure 11 - Average Monthly %eVMT, %zVMT & %e-Trips for Honda Accord Vehicles - All Trips.24Figure 12 - Average Monthly %eVMT, %zVMT & %e-Trips for Toyota Prius Vehicles - All Trips.24Figure 13 - Variability for eVMT .25Figure 14 - Percent eVMT vs. trips/day .26Figure 15 - Absolute eVMT vs. trips/day.26Figure 16 - Percent eVMT vs. Trip .26Figure 17 - Absolute eVMT vs. Trip Length .26Figure 18 - Percent eVMT vs. Daily VMT .27Figure 19 - Absolute eVMT vs. Daily VMT .27Figure 20 - Percent eVMT vs. Charge Events/day .27Figure 21 - Absolute eVMT vs. Charge Events/day .27Figure 22 - Percent eVMT vs. Level 2 Charge Events/day .28Figure 23 - Absolute eVMT vs. Level 2 Charge Events/day.28Figure 24 - Nissan Leaf Charge Location Percentages .29Figure 25 - Nissan Leaf Charge Type Percentages .30Figure 26 - Nissan Leaf Charge Type Percentages for Purchased vs. Leased Vehicles .30Figure 27 - Nissan Leaf Charge Type Percentages for Fleet vs. Private Vehicles .31Figure 28 - Nissan Leaf Charge Type Percentages for Leased Vehicles with Prepaid Miles .32Figure 29 - Nissan Leaf Charge Location & Type Percentages .32Figure 30 - Nissan Leaf Average VMT by DCFC events .33Figure 31 - Nissan Leaf Average mileage by percentage of DCFC events .33Figure 32 - Ford C-Max Average Monthly %eVMT, %zVMT, %eTrips and % Charge Counts byType.34G - iii

Figure 33 - Ford Fusion Average Monthly %eVMT, %zVMT, %eTrips and % Charge Counts byType.35Figure 34 - Ford Focus Average Monthly %eVMT, %zVMT, %eTrips and % Charge Counts byType.36Figure 35 - Honda Fit Monthly Charge Location Percentages .37Figure 36 - Honda Fit Monthly Charge Type Percentages .37Figure 37 - Honda Fit Monthly Charge Location & Type Percentages .38Figure 38 - GM Volt Monthly Charging .38Figure 39 - EMFAC2014 Adjustment Value for Start Emissions .40Figure 40 - Comparison of Approximate Soak Time Distributions in Minutes .41LIST OF TABLESTable 1 - Number of Vehicles in the BMW Dataset . 2Table 2 - Number of Vehicles in the Ford Dataset . 3Table 3 - Number of Ford Vehicles for California Trips . 4Table 4 - Number of Ford Vehicles for California Designated “Home State” Vehicles . 4Table 5 - Number of Vehicles in the General Motors Dataset . 5Table 6 - Number of General Motors Vehicles for California Designated “Home State” Vehicles 5Table 7 - Number of Vehicles in the Honda Dataset . 6Table 8 - Number of Vehicles in the Nissan Dataset . 7Table 9 - Number of Vehicles in the Tesla Dataset . 8Table 10 - Number of Vehicles in the Toyota Dataset . 8Table 11 - Summary of Vehicles in the ARB dataset . 9Table 12 – Summary of Number of Vehicles .10Table 13 - Annual VMT for BEVs .14Table 14 - Annual VMT for PHEV Vehicles .15Table 15 - Nissan Leaf Fleet Vehicles vs. Private Vehicles .19Table 16 - Nissan Leaf Leased Vehicles vs. Purchased Vehicles .19Table 17 - Pre-paid Annual Miles for Leased Nissan Leaf Vehicles.19Table 18 - Approximate Trips per Day .39Table 19 - Approximate Cold Starts per Day .42Table 20 - Annualized statistics of PEVs from INL, and UCD studies .49G - iv

I. IntroductionIn 2012, the California Air Resources Board (ARB or the Board) adopted the Advanced CleanCars (ACC) program, including increased requirements for the zero-emission vehicle (ZEV)regulation). When the increased requirements for the ZEV regulation were adopted, only twomanufacturers had certified plug-in hybrid electric vehicles (PHEV), 1 and little was known abouthow those vehicles would be driven, what the emissions benefits could be, how often thosevehicles would be plugged in, or how the second or third owners of the vehicles would drive orcharge the vehicles. Knowing there was much to learn about PHEVs and range extendedbattery electric vehicles (BEVx), the Board directed staff in Resolution 12-11 to study “in-usedata for range extended battery electric vehicles and plug-in hybrid electric vehicles, and, ifwarranted, propose appropriate modifications to treatment and credits for these vehicle types”.Soon after the Board adopted the ACC regulations, manufacturers (notably, Honda, Toyota,Ford, and General Motors) requested (both in front of the Board and duringmeetings with staff) that staff be directed to study the electric vehicle miles traveled (eVMT)from PHEVs as compared to BEVs. Manufacturers (General Motors, Ford, Toyota, and Honda)submitted trip level data to Idaho National Laboratory (INL) for analysis, which was laterpresented to the Board at its October 2014 hearing. 2 Since 2014, manufacturers havesubmitted the same trip level data (as well as additional data and data from othermanufacturers) for ARB to analyze.This Appendix G describes the in-use trip level vehicle data collected from various PHEVs,BEVs, and BEVxs. To provide a complete picture of how “ZEV-like” a PHEV is, staff analyzedtwo metrics, electric only trips (e-trips) and zero emission vehicle miles travelled (zVMT). Asseen from the data, driving data from the same vehicle model can vary widely dependent onwhen and under what driving conditions the data was collected. Vehicles with similar electricranges have varied eVMT and zVMT. The data also shows that EV project participants were alimited set of very early adopters and vehicles purchased by a broader group were lessinterested in maximizing %eVMT and %zVMT. Although newer PHEVs have higher VMT, theiraverage annual eVMT and zVMT remains constant. When possible, staff looked at data basedon California being the “home state”, and leased vehicles vs. purchased vehicles, and seasonaldifferences. Staff also analyzed the activity data received from manufacturers to betterunderstand the likely impacts on criteria pollutants such as hydrocarbons (HC) and oxides ofnitrogen (NOx) from the various PHEVs.This analysis will lead into Appendix I, which describes various ways to use data in this analysisin alternative credit schemes for PHEVs, BEVxs, and BEVs.II. Data OverviewSeven manufacturers submitted data for eleven different plug-in vehicle (PEV) models, whichincludes PHEVs, BEVxs, and BEVs. The data reported varied widely across manufacturers,and therefore analysis was limited for some models. This section will describe the type of dataToyota Plug-in Prius and Chevrolet VoltA description of INL’s analysis is found on page 52. A description of the Department of Energy’s EV Project isfound on page 51.12G-1

provided to staff, organized by manufacturer, as well as the number of vehicles included in eachdata set.II.A. Description of Data from ManufacturersII.A.1. BMWII.A.1.i. Type and Number of Vehicles in SampleVehicle data was provided for both the i3 BEV and the i3 with range extender (REX) which isthe only vehicle to date that is designated as a BEVx in the ZEV regulation. The number of BEVand BEVx vehicles sold in each year (not necessarily the model year), are listed in Table 1.Table 1 - Number of Vehicles in the BMW DatasetType of Plug-inModel Year/ RetailVehicleElectric VehicleYear/ 1st Record DateRetail Year 2014BMW i3 BEVBEVRetail Year 2015Retail Year 2016Retail Year 2014BMW i3 REXBEVxRetail Year 2015Retail Year 2016Number of Vehicles2,5251,654142,9765,29637II.A.1.ii. Location of Vehicles in SampleBMW provided a national dataset. There was no global positioning system (GPS) flag inthe data to break out the California or Section 177 ZEV state 3 vehicles.II.A.1.iii. Driving Data ProvidedBMW provided ARB with summary data tables that included, for each vehicle, the total vehiclemiles travelled (VMT) along with the corresponding total number of days since the vehicle wasplaced into service (sold or leased). A retail sales date was provided for each vehicle. Unlikethe data provided by most other manufacturers, the BMW data did not include details aboutindividual vehicle trips and thus, provided for more limited analysis in understanding how thevehicles were being used.II.A.1.iv. Charging Data ProvidedNo charging data was provided by BMW in the data sample.II.A.1.v. Data Exclusions and FilteringFor the BMW data sets, there was no additional processing of the data required prior to analysisas only summary data (total miles and days) and no individual trip data was provided. However,BMW indicated that the raw data attached have been filtered for read out errors such as counterresets, data transmission errors caused by mobile network connection loss and batteryThrough the provisions of the Clean Air Act identified as Section 177, nine states have adopted California’s ZEVregulation: Connecticut, Maine, Maryland, Massachusetts, New Jersey, New York, Oregon, Rhode Island, andVermont. These nine states are commonly referred to as the Section 177 ZEV states.3G-2

disconnects during dealer visits. Data collection was carried out through BMW internal TeleService Report (TSR) with customer consent.II.A.2. FORDII.A.2.i. Type and Number of Vehicles in SampleVehicle data was provided for the Focus BEV, the Fusion Energi PHEV and the C-Max EnergiPHEV. Details on the number of vehicles and model years within each vehicle are provided inTable 2 below.Table 2 - Number of Vehicles in the Ford DatasetType of Plug-inModel Year/ RetailVehicleElectric Vehicle Year/ 1st Record DateRetail Year 2012Retail Year 2013Retail Year 2014Ford FocusBEVRetail Year 2015ElectricRetail Year 2016unknownFord C-Max EnergiFord Fusion EnergiPHEVPHEVRetail Year 2013Retail Year 2014Retail Year 2015Retail Year 2016UnknownRetail Year 2013Retail Year 2014Retail Year 2015Retail Year 2016UnknownNumber of 4,9273,389768500II.A.2.ii. Location of Vehicles in SampleThe data provided by Ford included truncated global positioning system (GPS) data for each tripwhich allowed for a determination of the vehicle’s approximate location (only to within a hundredmile quadrant). As seen in Table 3, this data was used by ARB to determine if a vehicle wasprimarily being operated within California. Based on an analysis of the data, approximately 41%of the vehicles had the majority of their trips within California. The Ford Focus Electric had thelargest proportion of trips in California and the C-Max Energi had the lowest.G-3

Table 3 - Number of Ford Vehicles for California TripsVINs with 50% ofVehicleVINs with Trip Datatrips in CAFORD C-Max Energi10,2533,617FORD Focus4,2182,128ElectricFORD Fusion12,8425,439EnergiTOTAL27,31311,184% of VINs with 50% CA trips35.3%50.5%42.4%40.9%Ford provided additional data fields that indicated the “Home State” for each vehicle based onits own algorithm to determine the location of the vehicle. Ford’s data field provided similarresults compared to the staff’s analysis; with only a slightly larger number of vehicles designatedas California vehicles as seen in Table 4.Table 4 - Number of Ford Vehicles for California Designated “Home State” VehiclesVehicle Counts with % of Vehicles withVehicleVehicle CountsCA as Home StateCA as Home StateFORD C-Max Energi10,2534,39442.9%FORD Focus4,2182,42157.4%ElectricFORD II.A.2.iii. Driving Data ProvidedFord provided ARB with a large data set that included 125 data fields for each record, however,many of the fields were not relevant to the analysis. The relevant data fields related to drivingincluded: trip information that allowed ARB to determine fuel and electricity used for the trip; thetime, date, and distance of the trip; and information about the battery state of charge.II.A.2.iv. Charging Data ProvidedThe data provided included charging information indicating time and date of charging, type ofcharging (e.g., level 1, level 2), and information about the amount of charging that occurredduring each event.II.A.2.v. Data Exclusions and FilteringFor the Ford data set, the trip and charge data was extracted from the manufacturer’s data setto prepare for data consolidation in ARB’s analysis.II.A.3. GENERAL MOTORSII.A.3.i. Type and Number of Vehicles in SampleGeneral Motors provided ARB with data from the Chevrolet Volt PHEVs that were included inthe EV Project. The EV project is described later in Section 7 of this Appendix. This data set islimited in that it reflects a small number of vehicles relative to what GM has subsequently soldG-4

as well as that it represents a subset of early vehicle owners that were provided chargingequipment and voluntarily participating in a program to study their charging habits. Detailsregarding the number of vehicles and model years are provided in Table 5 below.Table 5 - Number of Vehicles in the General Motors DatasetType of Plug-inModel Year/ RetailVehicleElectric VehicleYear/ 1st Record DateMY 2011MY 2012Chevrolet VoltPHEVMY 2013UnknownNumber of Vehicles2071,1298171II.A.3.ii. Location of Vehicles in SampleGeneral Motors provided a national data set and a field denoting a State for each Chevrolet Voltbased on its own algorithm. No additional location information was provided as a means toverify or independently determine whether the vehicle was primarily used in California. Basedon the data set received, as shown in Table 6, approximately 31% of the vehicles wereCalifornia based vehicles.Table 6 - Number of General Motors Vehicles for California Designated “Home State”VehiclesTotal VehicleModel YearCA Vehicle Counts% CA i. Driving Data ProvidedGeneral Motors provided ARB with pre-processed data tables along with raw data tables for thesample vehicles. The driving data allowed staff to determine: the fuel and electricity used forthe trip; the time, date, and distance of the trip; and information about the battery state ofcharge.II.A.3.iv. Charging Data ProvidedGeneral Motors did not provide any location (home/work/other) or type (levels) data oncharges. However, staff came up with a logic for determining what counted as a charge andwere able to calculate total charge count.II.A.3.v. Data Exclusions and FilteringGM data utilized for this analysis is the same dataset included in the EV Project. As shown inTable 6, this dataset only spans over 2011 – 2013 model years. More information on EV projectis provided in Section 7 of this Appendix.G-5

II.A.4. HONDAII.A.4.i. Type and Number of Vehicles in SampleVehicle data was provided for both the Honda Fit BEV and the Honda Accord PHEV. Table 7provides details on the number of each vehicle and model year that were provided.Table 7 - Number of Vehicles in the Honda DatasetType of Plug-inModel Year/ RetailVehicleElectric VehicleYear/ 1st Record DateFirst Record Date inCY2012First Record Date inHonda FitBEVCY2013First Record Date inCY2014Honda AccordPHEVFirst Record Date inCY2012Number ofVehicles805596189II.A.4.ii. Location of Vehicles in SampleThe Honda dataset was a national dataset with no GPS information provided. However, most ofthose vehicles were sold in CA.II.A.4.iii. Driving Data ProvidedHonda provided ARB with a trip data table for each selected vehicle. Each vehicle’s trip datatable provides the records for each key-off event. The driving data allowed staff to determine:the fuel and electricity used for the trip; the time, date, and distance of the trip; and informationabout the battery state of charge.II.A.4.iv. Charging Data ProvidedHonda provided ARB with a charge data table for each selected vehicle. Each vehicle’s chargedata table provides the records for each charge-off event. The charging data allowed ARB todetermine the time, the presumed location (home/not home), the type of charging (e.g., level 1,level 2) for Fit EV charge events, and the battery state of charge information for both the AccordPHEV and the Fit EV.II.A.4.v. Data Exclusions and FilteringData was excluded for vehicles that had accumulated less than 90 days-worth of trips and for allresearch and testing vehicles. All data records prior to a vehicle’s retail start date wereexcluded. For the Honda Accord PHEV, additional records were excluded for vehicles with lessthan 1000 miles and for all vehicles when a customer does not have a paired phone to transmitdata. For the Honda data set, the trip and charge data was extracted from the manufacturer’sdata set to prepare for data consolidation in ARB’s analysis.G-6

II.A.5. NISSANII.A.5.i. Type and Number of Vehicles in SampleVehicle data was provided for the Nissan Leaf BEV. Table 8 below provides details on thenumber of each vehicle and model year that were provided.Table 8 - Number of Vehicles in the Nissan DatasetType of Plug-inModel Year/ RetailVehicleElectric VehicleYear/ 1st Record DateMY 2011MY 2012Nissan LeafMY 2013BEVMY 2014MY 2015Number of Vehicles4,0522,8674,0431,15598II.A.5.ii. Location of Vehicles in SampleData was provided for vehicles determined by Nissan to be California-based vehicles. Nissanonly sent data for vehicles with great than 50% of trips in CA so all records sent are consideredCalifornia based vehicles. For those vehicles, data was provided for vehicle trips within andoutside of California, which can be approximated by using the truncated GPS data fields. Dataprovided to ARB included a subset of the vehicles from the EV Project (i.e., only the Californiabased vehicles) as well as additional California-based vehicles that were not a part of the EVProject.II.A.5.iii. Driving Data ProvidedNissan provided ARB with a trip data table and a vehicle table. A data dictionary was alsoprovided. The vehicle table allowed ARB to determine the model year, on-board charger rating,and purchase agreement data that indicated whether the vehicle was purchased or leased and,if leased, the annual mileage limitations of the lease agreement (i.e., 12,000 or 15,000 annualmiles pre-paid). The data also indicated whether the vehicle was privately owned or purchasedfor a fleet. The driving data allowed ARB to determine the time, date, and distance of the trip,and information about the battery state of charge.II.A.5.iv. Charging Data ProvidedNissan provided ARB with a charge data table. The charging data allowed ARB to determine thetime and date of charging events, the type of charging (e.g., level 1, level 2, direct current or DCfast charge), information about the battery state of charge (SOC), and information about thecharging location (inferred location of home/work/other per Nissan proprietary algorithm).II.A.5.v. Data Exclusions and FilteringData for 2011 through 2012 model year vehicles was subject to a trip-by-trip approval by thedriver to transmit the data to Nissan. As a result, a significant portion of the trip data is missingfor these model years. Data for 2013 through 2015 model year vehicles was subject to amonthly approval by the driver and resulted in more complete data records. Data was excludedfor vehicles that had accumulated less than 90 days worth of trips and for records with odometervalues less than 124 miles (200 kilometers) to avoid transport and dealer use. Some additionalG-7

records were excluded due to invalid data in critical fields. For the Nissan data set, the trip andcharge data were extracted from the manufacturer’s data set to prepare for data consolidation inARB’s analysis.II.A.6. TESLAII.A.6.i. Type and Number of Vehicles in SampleTesla provided ARB with data for Model S BEVs. Table 9 below tabulates the number ofvehicles in the sample set that were placed in service each year (not necessarily model year).Table 9 - Number of Vehicles in the Tesla DatasetType of Plug-inModel Year/ RetailVehicleElectric VehicleYear/ 1st Record DateFirst Record Date in CY2012First Record Date in CY2013Tesla Model SBEVFirst Record Date in CY2014First Record Date in CY2015Number ofVehicles22918,74910,9677,690II.A.6.ii. Location of Vehicles in SampleThe data included vehicles placed in the United States.II.A.6.iii. Driving Data ProvidedTesla provided ARB with a pre-filtered summary table that included the beginning and endingodometer and dates, the recorded miles and days, and the annual run-rate (the annualizedvehicle miles travelled based on 365 days per year).II.A.6.iv. Charging Data ProvidedNo charging data was provided in the Tesla data sample.II.A.6.v. Data Exclusions and FilteringTesla provided ARB with a pre-filtered summary table that only included vehicles that had atleast 30 days of recorded data and a minimum of 3,000 recorded odometer miles. For the Tesladata set, there was no additional processing of the data required prior to analysis as onlysummary data (total miles and days) and no individual trip data was provided.II.A.7. TOYOTAII.A.7.i. Type and Number of Vehicles in SampleToyota provided ARB with data for Prius PHEVs. Table 10 below provides details of thenumber of vehicles by year the vehicle was placed in service (not necessarily model year) thatwere included in the sample.Table 10 - Number of Vehicles in the Toyota DatasetType of Plug-inModel Year/ RetailVehicleElectric VehicleYear/ 1st Record DateFirst Record Date in CY2013Toyota PriusPHEVFirst Record Date in CY2014G-8Numbe

manufacturers had certified plug-in hybrid electric vehicles (PHEV) , 1. and little was known about how those vehicles would be driven, what the emissions benefits could be, how often those vehicles would be plugged in, or how the second or third owners of the vehicles would drive or charge the vehicles.

Related Documents:

Algebra 2 - Midterm Exam Review The Algebra 2 Midterm Exam must be taken by ALL Algebra 2 students. An exemption pass may be used to exempt the score for the Algebra 2 Midterm Exam. It should be presented to your teacher prior to taking the exam. The Algebra 2 Midterm Exam will consist of 30 multiple choice questions.

Read the text "Smart Cars for Clean Air" before answering Numbers 1 through 5. Smart Cars for Clean Air Cars take us to school, work, and anywhere else we want to go. We rely on cars to get us to a wide variety of places . . . and fast! There is no doubt that the automobile has made our lives easier in a number of ways. But there is also no

Read the article "Smart Cars for Clean Air" before answering Numbers 1 through 10. Smart Cars for Clean Air Cars take us to school, work, and anywhere else we want to go. We rely on cars to get us to a wide variety of places and fast! There is no doubt that the automobile has made our lives easier in a number of ways.

fuel cell electric vehicles, or FCEV) and plug-in hybrid electric vehicle (PHEV) technology has progressed quickly. This has led to introductions (and announcements) of vehicles with longer ranges and more efficient and capable drivetrains far earlier than expected.

Jan 18, 2017 · Increased pure ZEV and plug-in hybrid electric vehicle (PHEV) sales (100% of new vehicle sales by 2050), beyond regulation minimum compliance in 2025. . Regarding the eVMT fraction assumption, some current vehicles such as the 2017 Chevrolet Volt are likely to already exc

Californias Advanced Clean Cars Midterm Review . Appendix B: Consumer Acceptance of Zero Emission Vehicles and Plug-in Hybrid Electric Vehicles

Background theory on Coherent Anti-Stokes Raman Scattering (CARS) ! CARS Instrumentation ! Brief Introductions to F-CARS, E-CARS, M-CARS ! Application of CARS to cell imaging ! Applications ! Summary . Live cell imaging requires the development of new optical microscopy methods ! Specificity

Schiavo ex rel. Schiavo, _ F.3d _, 2005 WL 648897 (11th Cir. Mar. 23, 2005) (Schiavo I), stay denied, _ S. Ct. _, 2005 WL 672685 (Mar. 24, 2005). After that appeal was taken, the plaintiffs filed an amended complaint on March 22, 2005, adding four more counts, and a second amended complaint on March 24, 2005, adding a fifth count. On the basis of the claims contained in those new .