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Windage trays are meant to prevent this sort of parasitic loss from oil splashing onto the crank and to shield the sump oil from windage effects. Many trays have scraper louvers built into them that strip away oil from the windage cloud.
It is a common misperception that a windage cloud will not form because of a windage tray and that a windage cloud comes primarily from splashing oil in the sump. The latter might be true during abrupt manuevers but during steady driving a windage cloud will form with or without a tray in place.