The deployment of next generation lunar laser retroreflectors is planned in the near future. With proper robotic deployment, these will support single shot single photo-electron ranging accuracy at the 100 micron level or better. There are available technologies for the support at this accuracy by advanced ground stations, however, the major question is the ultimate limit imposed on the ranging accuracy due to the changing timing delays due to turbulence and horizontal gradients in the earth’s atmosphere. In particular, there are questions of the delay and temporal broadening of a very narrow laser pulse. Theoretical and experimental results will be discussed that address estimates of the magnitudes of these effects and the issue of precision vs. accuracy.