In The Permit Power Revisited, Professors Biber and Ruhl make a well-articulated and easy to follow argument for a regulatory shift along the “spectrum of [permitting] approaches” from “specific permits” to the more favored “general permits.” At least in the context of the CWA, the Biber/Ruhl article is timely and adds great value to the continuing legal and policy debate on alternatives to tackling some of the intractable environmental problems that continue to elude our aging regulatory programs. While individual permits will continue to be the most effective tool for regulating individuated pollution sources with greater potential for environmental harm, despite the intensive resources required, shifting toward general permits that are cheaper to enter, easier to renew and create less administrative burdens on agencies and the regulated community is the wave of the future. Herein, Biber and Ruhl have provided a useful rationale and roadmap for making that transition.