Microwave measurements of the ocean-roughened surface have been collected during several recent international experiments using an airborne radiometer observing at 89 and 157 GHz. The purpose of this project is to test and validate the sea emissivity model required for the future humidity sounder, advanced microwave sounder unit B, over a wide range of atmospheric and surface conditions. In this paper, the measurements are statistically analyzed and compared with a geometric optics model with special emphasis on the sensitivity to the input parameters. This model is shown to provide good overall agreement with the data when coupled to the wave slope description of Cox and Munk (1954), the liquid water dielectric permittivity of Liebe et al. (1991), and the foam coverage of Monahan and Lu (1990), after increasing the theoretical predictions by a bias of about 2.5 K at 89 GHz and 1.7 K at 157 GHz. In addition, an empirical emissivity algorithm derived from low-frequency observations (Hollinger, 1971; Stogryn, 1972) and widely used for satellite retrieval purposes is shown to be inappropriate for use at millimeter frequencies.