Bungay et al. [Phys. Lett. A 174, 335 (1993)] reported observing polar
ization plane rotation in optical reflection at normal incidence from
GaAs, an effect that they term specular optical activity. Their prefer
red interpretation hypothesizes a partially symmetric third-rank bulk
tensor arising from nonlocality, even though its existence would viola
te time reversibility. We present an alternative explanation based on
the derived properties of a nonlocal surface layer that preserves time
reversibility. (C) 1998 Optical Society of America.