[honk]

This reference instrument variability is especially true of the BAM, which due to its measurement technology has a high "noise floor" at low concentrations, while remaining a fairly good measurement at high concentrations. I believe two identical BAMs next to each other can easily have more than 25% disagreement at the lower end of the concentration range.

The T640 also recently had its approved calibration algorithm(s) updated, to a new set which often reads about 7% lower. What does that mean for T640 reference data collected in the past? I don't know, and AFAIK neither does the EPA really.

All that to say that reference instruments are still instruments with limitations, even if from a regulatory perspective we treat them as "truth".