it depends on the plants that you plan to have under or near the output flow of the filter. i have a huge amazon sword half under the flow from an Aquaclear 110 set to full flow, and it is thriving like you wouldn't believe. i also keep my water level down an inch or so to help with oxygenation, which creates more surface disruption. my plants flow like they would in a not too lazy river, lol.
tough plants would do well planted near the output, whereas more flimsy stem plants or floating plants would want a fairly still area to grow in.
edit: sometimes my marimo moss balls get stuck in a jetty from the filter output and i sing the 'rollin' rollin' rollin'....' song, lol!