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Uncertainty in the wind speed is a major source of error in passive microwave measurements from satellites of sea surface temperature (SST) because of the non-linear relationship between sea surface emissivity and wind speed. The accuracy of the SST measurement that can be achieved with only passive microwave measurements was assessed by computer modeling. Our investigation showed that the second-order terms must be included in the equation of radiative transfer in an analysis of the errors in the retrieved SST. In addition, we found that the effects of wind roughening and foam production should be treated separately. We have concluded that the accuracy of SST measurements would be improved by including data from an active remote-sensing instrument such as a scatterometer.