The highest resolution images of Comet 19P/Borrelly show many dark features which, upon casual inspection, appear to be low albedo markings, but which may also be shadows or other photometric variations caused by a depression in the local topography. In order to distinguish between these two possible interpretations we conducted a photometric analysis of three of the most prominent of these features using six of the highest quality images from the September 22, 2001 Deep Space 1 (DS1) flyby. We find that: 1. The radiance in the darkest parts of each feature increases as phase angle decreases, similarly to the radiance behavior of the higher albedo surrounding terrain. The dark features could be either fully illuminated low albedo spots or, alternatively, they could be depressions. No part of any of the three regions was in full shadow. 2. One of the regions has a radiance profile consistent with a rimmed depression, the second, with a simple depression with no rim, and the third with a low albedo spot. 3. The regolith particles are backscattering and carbon black is one of the few candidate regolith materials that might explain this low albedo. We conclude that Borrelly's surface is geologically complex to the limit of resolution of the images with a combination complex topography, pits, troughs, peaks and ridges, and some very dark albedo markings, perhaps a factor of two to three darker than the average 3-4% albedo of the surrounding terrains. Our technique utilizing measured radiance profiles through the dark regions is able to discriminate between rimmed depressions, rimless depressions and simple albedo changes not associated with topography. ?? 2003 Elsevier Inc. All rights reserved.