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A study of the sources of variability in particulate measurements using the Heavy-Duty Transient Test (40 CFR Subpart N) has been conducted. It consisted of several phases: a critical examination of the test procedures, visits to representative facilities to compare and contrast facility designs and test procedures, and development of a simplified model of the systems and procedures used for the Heavy-Duty Transient Test. Some of the sources of variability include; thermophoretic deposition of particulate matter onto walls of the sampling system followed by subsequent reentrainment in an unpredictable manner, the influence of dilution and cooling upon the soluble organic fraction, inconsistency among laboratories in the engine and dynamometer control strategies, and errors in measurements of flows into and out of the secondary dilution tunnel.