1. Visual acuity varies in a definite manner with the illumination. At low intensities visual acuity increases slowly in proportion to log I; at higher intensities it increases nearly ten times more rapidly in relation to log I; at the highest illuminations it remains constant regardless of the changes in log I. 2. These variations in visual acuity measure the variations in the resolving power of the retina. The retina is a surface composed of discrete rods and cones. Therefore its resolving power depends on the number of elements present in a unit area. The changes in visual acuity then presuppose that the number of elements in the retina is variable. This cannot be true anatomically; therefore it must be assumed functionally. 3. To explain on such a basis the variations of visual acuity, it is postulated that the thresholds of the cones and of the rods are distributed in relation to the illumination in a statistical manner similar to that of other populations. In addition the rods as a whole have thresholds lower than the cones. Then at low intensities the increase in visual acuity depends on the augmentation of the functional rod population which accompanies intensity increase; and at higher intensities the increase in visual acuity depends on the augmentation of the functional cone population. The number of cones per unit foveal area is much greater than the number of rods per unit peripheral area, which accounts for the relative rates of increase of rod and cone visual acuity with intensity. At the highest illuminations all the cones are functional and no increase in visual acuity is possible. 4. If this division into rod visual acuity and cone visual acuity is correct, a completely color-blind person should have only rod visual acuity. It is shown by a study of the data of two such individuals that this is true. 5. The rod and cone threshold distribution has been presented as a purely statistical assumption. It can be shown, however, that it is really a necessary consequence of a photochemical system which has already been used to describe other properties of vision. This system consists of a photosensitive material in reversible relation with its precursors which are its products of decomposition as well. 6. On the basis of these and other data it is shown that a minimal retinal area in the fovea, which can mediate all the steps in such functions as visual acuity, intensity discrimination, and color vision, contains about 540 cones. Certain suggestions with regard to a quantitative mechanism for color vision are then correlated with these findings, and are shown to be in harmony with accurately known phenomena in related fields of physiology.