I've just gone through the experience of removing botg the upper and lower covers myself. The labor involved in getting the lower off was much more than the top. The top was easy.
I find it much more likely that any oil leak would come from the bottom, not the top. I think there is much more oil flying around the lower, not the upper.
'05 E320 CDI - 86,000 miles
'86 300SDL - 360,000 miles
'85 300SD - 150,000 miles (sold)
'89 190D - 120,000 miles (sold)
'85 300SD - 317,000 miles (sold)
'98 ML320 - 270,000 miles (sold)
'75 300D - 170,000 miles (sold)
'83 Harley Davidson FLTC (Broken again) :-(
'61 Plymouth Valiant - 60k mikes
2004 Papillon (Oliver)
2005 Tzitzu (Griffon)
2009 Welsh Corgi (Buba)