I'd disagree with this, based on personal experience. I have a 75 gallon heavily planted tank with pressurized CO2, dosed, 216w of T5 sitting over the top of it, an XP4, a couple small powerheads, and eco substrate. I think its fair enough to call it high tech and well setup.
However, with my CO2 off, with minimal surface agitation, adjusted by the placement of my XP4 spraybar, the oxygen level in the water is lower than when the spraybar is adjusted to increase surface agitation.
The lower oxygen content in the water column is evidenced by the more oxygen sensitive fish in the tank frequently gasping at the surface and showing signs of having difficulty breathing. I even lost 1 of them because of it. As soon as I increased surface agitation(still with my CO2 setup off), everyone perked right up and became much more active.