Reflectrometric measurements provide an objective assessment of the directionality of the photoreceptors in the human retina. Measurements are obtained by imaging the distribution at the pupil plane of light reflected off the human fundus in a bleached condition. We propose that scattering as well as waveguides must be included in a model of the intensity distribution at the pupil plane. For scattering, the cone-photoreceptor array is treated as a random rough surface, characterized by the correlation length T (related to the distance between scatterers, i.e., mean cone spacing) and the roughness standard deviation (assuming random length variations of the cone outer-segment lengths that produce random phase differences). For realistic values of T and we can use the Kirchhoff approximation for computing the scattering distribution. The scattered component of the distribution can be fitted to a Gaussian function whose width depends only on T and . Actual measurements vary with experimental conditions (exposure time, retinal eccentricity, and ) in a manner consistent with the scattering model. However, photoreceptor directionality must be included in the model to explain the actual location of the peak of the intensity distribution in the pupil plane and the total angular spread of light.