The EM vacuum fluctuations are likely fluctuations in the gravitational potential field, vibrational strong coupling zero point energy
The “zero point EM fluctuations” are most likely gravitational energy density fluctuations. At the surface of the earth, the gravitational energy density is equivalent to a magnetic field of about 360 Tesla, the peak is about 1500 eV. The distribution is approximately black body and extends through soft x-ray and XUV down to thermal. The reason you do not need photons, is the photons are vacuum states of the gravitational potential field. The “grain” of the field is roughly 7 million times smaller than the electron. But there might be more than one small Fermion involved.
The peak intensities for lightning on earth and magnetic recombination on the sun are capped by the respective gravitational energy density. the gamma rays and pair production statistics match.
You can perhaps check fairly easily. Your experiments, run for a few days, would follow the vector sun moon tidal gravity signal. You can compare to a superconducting gravimeter, or a high sensitivity broadband three axis seismometer, or tensor gravimeter.
High harmonic generation for XUV yields is likely connected to the same sqrt(Nph+1) process.
Richard Collins, The Internet Foundation