The Bulk Photovoltaic effect is the means by which ferroelectric materials can generate electrical power from incident light. A resurgence of interest in ferroelectric materials has led to some speculation that the bulk ferrorelectric effect could improve solar power conversion efficiency. In a recent paper "Energy Conversion Efficiency of the Bulk Photovoltaic Effect" published in PRX Energy, Andreas Pusch and co-authors show that the power conversion efficiency of a bulk photovoltaic device is necessarily low owing to a very strict tradeoff between the photovoltage and electrical conductivity required to enable high power devices. We conclude that the efficiency of any practical bulk photovoltaic device will fall a long way short of the semiconductor Shockley-Queisser efficiency limit.