In a previous Letter [M. Schulkin, J. Acoust. Soc. Amer.44, 1152(L), (1968)], an empirical relation was presented for wind‐speed controlled losses in ocean‐surface duct propagation. which holds over a wide range of frequencies (1.5 to 25 kHz) and waveheights. This relation isas= 1.64 (fh)1/2 dB limiting ray cycle, wherefis the acoustic frequency in kilohertz andhis the mean crest‐to‐trough waveheight in feet. In this Letter, evidence is presented that this behavior can result front the combined effect of (1) bubble‐density distribution with a tail that falls off approximately asR−7.2, whereRis the bubble radius; (2) bubble‐volume concentration decaying with depthzapproximately as a ɜ−1.2modified by a small dependence on layer depth and hydrostatic pressure; and (3) bubbles that mostly originate from breaking wind waves.