to characterize the before and after full Moon radiance variation for a typical highlands site and a typical mare site. Focusing on the phase angle range 45°< a < 50°, we test two different physical models, macroscopic roughness and multiple scattering between regolith particles, for their ability to quantitatively reproduce the measured radiance difference. Our method for estimating the rms slope angle is unique and model-independent in the sense that the measured radiance factor I/F at small incidence angles (high Sun) is used as an estimate of I/F for zero roughness regolith. The roughness is determined from the change in I/F at larger incidence angles. We determine the roughness for 23 wavelengths from 350 to 939 nm. There is no significant wavelength dependence. The average rms slope angle is 22.2°± 1.3°for the mare site and 34.1°± 2.6°f or the highland site. These large slopes, which are similar to previous ''photometric roughness" estimates, require that sub-mm scale ''micro-topography" dominates roughness measurements based on photometry, consistent with the conclusions of Helfenstein and Shepard (Helfenstein, P., Shepard, M.K. [1999]. Icarus 141, 107-131). We then tested an alternative and very different model for the before and after full Moon I/F variation: multiple scattering within a flat layer of realistic regolith particles. This model consists of a log normal size distribution of spheres that match the measured distribution of particles in a typical mature lunar soil 72141,1 . Proc. Lunar Sci. Conf. 5, Geochim. Cosmochim. Acta 1 (5), 887-906). The model particles have a complex index of refraction 1.65-0.003i, where 1.65 is typical of impact-generated lunar glasses. Of the four model parameters, three were fixed at values determined from Apollo lunar soils: the mean radius and width of the log normal size distribution and the real part of the refraction index. We used FORTRAN programs from