Co-authors Eric Biber and J.B. Ruhl should be commended for providing a thoughtful framework for when agencies should consider individual versus general permitting regimes. They presented a similar framework for the Administrative Conference of the United States, which is a helpful forum for airing perspectives on important administrative law topics. While Biber and Ruhl discuss some of the key factors for agencies in designing a permitting scheme, we identify some areas where they may have relied on overly generalized assumptions and suggest additional considerations they could take into account in their model.