Determination of the true temperature of the near-surface water of the sea using an airborne ir radiometer requires a knowledge of the vertical temperature and water vapor distribution in the intervening atmosphere, the sky radiation reflected from the sea, and the temperature drop across the thermodynamic skin at the air-water interface. Current techniques may lead to errors of several degrees. In addition, there is radiometric noise of the order of 1°C owing to aircraft motion, inhomogeneities in the atmosphere, and radiometric clutter on the surface of the sea.
H. L. Clark, "Some Problems Associated with Airborne Radiometry of the Sea," Appl. Opt. 6, 2151-2157 (1967)