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A derivation of the Planck spectrum for thermal radiation is given based upon wave fluctuations within relativistic classical physics. The derivation depends crucially on thermal fluctuations existing above the fundamental inertial-frame-independent fluctuations of classical zero-point radiation. Such frame-independent zero-point fluctuations exist only in a relativistic wave theory and cannot exist in a nonrelativistic wave theory. Thus such a classical derivation of the Planck spectrum exists in a Lorentz-covariant classical theory, such as classical electrodynamics, but not in a Galilean-covariant theory where all waves are based upon material media. Classical zero-point radiation provides a purely classical alternative to quanta in the analysis of the Planck spectrum.
Timothy H. Boyer (Mon,) studied this question.