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Shibatani 1973 has suggested that surface phonetic constraints are a necessary part of a psychologically real grammar. I claim that, in addition, such constraints are sufficient—that they are the only true generalizations in a generative grammar, and that morpheme-structure conditions play no independent role (and thus have no place) in phonological theory. Both synchronic and diachronic arguments for this position are presented. An implication of this claim for phonological theory, aside from the obvious change in the form of a grammar, is that, without the possibility of referring to the simplicity of MSC's, analyses based on certain assumptions about the nature of underlying representations can no longer claim support from the theory.