This is only true when a tank has a UGF filter system. Nitrifying bacteria are aerobic bacteria, meaning they need HIGH oxygen levels in their water in order to thrive. With a UGF filter, where the filter is pulling the water down through the gravel and then returns it back through the uplift tubes, this would be true BUT for all other filters systems, the gravel, other than the very top surface areas, gets very little oxygen compared to other areas of the tank and especially when compared to all of the surface area on other filter media. A single section of filter floss pad or even a single piece of specialized biological filter media that is very porous with miles of microscopic tunnels, has more surface area than all of the gravel combined. Further, the nitrifying bacteria are going to set up home where the food is and the filter media has all the water (with ammonia, nitrites, oxygen) flowing through it on a constant and rapid basis compared to the gravel which just has some of the water touching it as it circulates.
Dr. Tim Hovenac, the inventor of the BioWheel and many other patented products like Dr. Tim's One And Only live nitrifying bacteria (even did his PhD on nitrifying bacteria in aquaria) has said and written this many times over the years... so it's not just me saying it.