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There is no limit on the level that the reflections can be at and in a modern environment, such as a city, the albedo can increase the power levels many times of the sky based solar radiation of direct and diffuse combined. The trees prevent the albedo reflections from occurring.

Steven Magee , in Solar Radiation, Global Warming and Human Disease
power trees city sky limit environment reflections modern direct prevent level radiation increase solar radiation-effects albedo diffuse occurring