The effect of S/N from +20 to -10 db on loudness levels of connected discourse with or without background cafeteria noise was investigated for one set of instructions sampling the most comfortable loudness level (MCLL) and a second set sampling the upper limit of CLL. Normal young adults (N:16) showed no significant differences for either set of instructions in quiet or from 20 to 0 db S/N but mn MCLL was about 5 db lower at -10 db. Elderly hearing-aid wearers (N:10, mn age: 77 yrs) yielded mn differences across S/N of less than 5 db for either set of instructions. No data indicate that the speech CLL accurately predicts optimal hearing-aid gain, while the literature indicates that occasionally the desired maximum intelligibility frequently is not obtained at the MCLL. We question whether MCLL for speech justifies its measurement. A discussion is presented of the Comfort Level Method of adjusting gain in hearing-aid evaluations and a perhaps preferable Threshold Level Method in which the test stimulus is presented at a level corresponding to the predicted threshold and the aid's volume control is adjusted until S just perceives the signal.