This can happen in non-planted, non co2 tanks as well, I know cause it use-to happen to me after my 50% water-changes. I first remedied the situation by having a micro bubble wand and air pump standing by at the 1st sign of labored breathing. Then I discovered if I use a garden sprayer adjusted to a spray pattern that was both wide and high-flow that my measures O2 levels would actually be higher then when I started the water-change, and a huge difference in the end between just pouring the water in (no-nozzle spray) resulting in 5 PPM (death zone) and below O2 readings, and 8 to 9 PPM (max zone) when filling the tank using a sprayer. This is especially true in the summer southwest if your city water is gravity fed warm water between 80 and 90 F out of the cold side will be depleted of O2 and spray filling makes all the difference between happy and dieing fish and will also lower the exit temperature of the water by 5 F. I do all ma fish y 1200 gallons of water changes using a $3 spray nozzle and have never had fish gasp syndrome since.
Oh, it also helps the water vent off chlorine and chloramines it exchanges for O2 in the spray process