In this paper it is maintained that L2 phonological acquisition is different from child L1 acquisition, but not as it relates to accessibility to Universal Grammar. While adults can acquire new phonemic categories and access universal phonological constraints, this paper proposes that the manner in which newly acquired target phonological processes can be fixed in the sense of a steady state in adulthood is fundamentally different. Offering the Constraint Fluctuation Hypothesis (CFH), which assumes Optimality Theory (OT), it is acknowledged that L2 constraint reranking is possible but never achieves a steady state as in L1 acquisition. If on the right track, the CFH reconciles documented optionality in L2 phonological production within the ...