It seems situational. Someone with your skin at noon absolutely benefits from a higher SPF. Someone with even slightly darker skin [0] going out a few hours before sunset might still want to wear sunscreen, especially if they’re going to be in direct sun the whole time, but a high SPF doesn’t seem very critical.

That being said, I am not a dermatologist, and it’s easy to underapply sunscreen so erring on the side of higher SPFs probably makes sense.

[0]: Note that even people with a lot of melanin still need sunscreen: https://www.pbs.org/newshour/amp/health/why-its-important-ev...