A huge discrepancy between the zero-point energy calculated from quantum theory and the observed quantity in the Universe has been one of the most illusive problems in physics. In order to examine the measurability of zero-point energy, we construct reference frames in a given measurement using observables. Careful and explicit construction of the reference frames surprisingly reveals that not only is the harmonic oscillator fluctuating at the ground level, but so is the reference frame when the measurement is realized. The argument is then extended to examine the measurability of vacuum energy for a quantized electromagnetic field, and it is shown that while zero-point energy calculated from quantum theory diverges to infinity, it is not measurable.
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