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The Second Law can be illustrated with a hose used as a siphon to empty a swimming pool, for example. It works if the other end of the hose goes down a slope and is significantly below the bottom of the pool.
The water flows and entropy increase because we have a single process. The SLoT requires a single process, as is obvious in everyday life.
If you cut the hose at the highest point you now have two processes, and the water no longer goes upwards from the pool.
Any heat flow from a cooler atmosphere to a warmer surface is a single completed process. The energy is not constrained to return by radiation or to do anything in particular. It could be conducted elsewhere in the surface for example.
Because it is a single process from atmosphere to surface, there is no justification fro saying that any subsequent process can create a net effect and thus excuse the violation of the Second Law. It would be like water flowing uphill to the town’s water tank on the basis that it would subsequently flow further downhill through pipes into houses. But there is no constraint enforcing this, as there was with the siphon before the hose was cut. After all, the tank might leak.
Hence, thermal energy cannot transfer spontaneously from a cooler atmosphere to a warmer surface. Fullstop.
See my publication Radiated Energy and the Second Law of Thermodynamics
www.webcommentary.com/docs/jo120314.pdf
I’m guessing that one can’t get any lower than the WWF so they’re able to siphon off everything.