Poor man's method:
Let' say you have a photo of the most magnificent medieval castle in known space, so magnificent that even though it's in France, the Rosbifs from across the Channel have elected it as the set of one of their medieval TV series, and the logo of a well-known American entertainment company has been inspired by it. Unfortunately this photo lacks contrast on the castle:
Attachment:
NoSkySelection-PoorMans1.jpg [ 92.62 KiB | Viewed 3811 times ]
Duplicate image layer, gaussian 2px and set to difference mode. New layer from visible, apply threshold (fairly low value). In my experiment there is a range of threshold values where you don't get any spots in the sky while the rest of the image starts to fill up.
Attachment:
NoSkySelection-PoorMans2.jpg [ 127.59 KiB | Viewed 3811 times ]
Filter/generic/dilate a couple of times to join the pixels, and gaussian blur to feather the upcoming selection:
Attachment:
NoSkySelection-PoorMans3.jpg [ 90.5 KiB | Viewed 3811 times ]