My most intense challenge layout for TMCC signal reception has multiple levels with some elevated tracks parallel to and generally running above the base level tracks. The layout has lots of bridges, accessories, building, and scenery that limited access for installing a ground plane enhancement. I chose to use a single strip of 2" wide aluminized tape on the underside of the upper level plywood because it could be applied easily to the existing finished layout - particularly in tunnels. It works fine. I also used a single wire for some of the installation.
I would not try to coat the entire underside of an upper platform with a ground plane. As previously described, the TMCC receiver measures the voltage differential between the track (outside rails) and the antenna. Too much of either signal component can swamp the receiver as is the case of multiple adjoining tracks or overhead tracks without a ground plane enhancement. Its a matter of balance.
When building a layout, using a wire on the underside of upper levels over track works fine - it can be installed during construction. For existing layouts, access around a multitude of accessories and scenery items becomes a challenge to attach a wire. Copper foil tapes may be a most suitable solution as they come is widths from 1/8" and up. Aluminum foil tape is less expensive and readily available at local hardware stores. I found that it sticks nicely to the underside of plywood in tunnels where access is a long reach.
Other TMCC gremlins are metal accessories that use the "common" ground of the track as is common practice on conventional layouts. Metal signals cause a signal loss near the signal when the accessory ground is shared with the track.
Metal truss bridges should be isolated from the track ground rails. A ground plane wire is then run through the bridge, or the bridge can then be connected to the ground plane. I had concerns that a metal bridge, that is connected to the ground plane and completely surrounds the locomotive as is passes through would swamp the TMCC signal reception, but found that operation through the bridges was flawless.
A single-level layout does not generally need ground plane enhancements. The ground plane signal emanating from the house wiring in the walls and ceiling of the layout room will be strong enough. Adding ground plane signal under the single level track is probably unnecessary. Exceptions are track-dense yards and turntable whisker tracks.
A multiple level layout will broadcast the rail signal component from the upper tracks and swamp the weaker ground plane signal coming from the house wiring. These areas need to boost the ground plane signal with a wire or metal tape ABOVE the tracks. A single wire/tape will probably suffice for several of the lower level tracks. YMMV and you may need to use more wire/tape. Test, rinse and repeat.
Always test the ground plane wire/tape with a multimeter to ensure it is not cross connected with the track rails.