The precision with which visual information can be recalled from working memory declines as the number of items in memory increases. This finding has been explained in terms of the distribution of a limited representational resource between items. Here we investigated how the sensory strength of memoranda affects resource allocation. We manipulated signal strength of an orientation stimulus in two ways: we varied the internal (sensory) noise by adjusting stimulus contrast, and varied the external (stimulus) noise by altering the within-stimulus variability. Both manipulations had similar effects on the precision with which the orientation could be recalled, but differed in their impact on memory for other stimuli. These results indicate that increasing internal noise released resources that could be used to store other stimuli more precisely, increasing external noise had no such effect. We show that these observations can be captured by a simple neural model of working memory encoding, in which spiking activity takes on the role of the limited resource.