This paper questions a recent claim (Gregg, 1989) that a first-order understanding of the link between internal waves and turbulence has been achieved. It is demonstrated (1) the theoretical basis of this result is extremely sensitive to an ad hoc assumption about the nature of the wavelength at which wave energy is delivered to dissipation (turbulence), (2) the method used by Gregg (1989) to calculate instantaneous wave field energy level E is incorrect and will seriously underestimate E in cases where E is greater than EGM, the energy level of the GM (Garrett and Munk, 1975) canonical internal wave field, and (30 the range of variation of E and buoyancy frequency N in the data sets reported by Gregg (1989) is not sufficient to rule out alternative scalings. ¿ American Geophysical Union 1990