A nonparametric SSB model, derived using the TOPEX altimeter, is analyzed to show a new decomposition of the form SSB = bH(s) + f(sigma (o)), where b is 0.03 and the function of radar cross section (sigma (o)) is an absolute second-order range correction residing outside the conventional nondimensional SSB model. Expected variability in the dominant bH(s) term and its ties to the long wave orbital velocity and shorter-scale slope variances are discussed using a physic ally-motivated restatement of recent EM bias theory. The geometry of steep near-breaking waves, neglected within current theory, is invoked as one plausible explanation for the observed H-s-independent SSB component.