I believe this is a new recommendation? Can you expand on this in the context of RFS and XFS? Happy to start a new thread if needed as it sounds like quite an important consideration.
He prefaced his opinion with "Personally" so I don't think he meant that this was an official recommendation, or even a generally held recommendation, although I believe it may be. Someone who works at LimeTech is allowed to have personal opinions, right?
I agree with him that it's always wise to leave some free space, especially if it's ReiserFS involved. I'm not sure we have enough evidence to say the same for XFS. XFS does seem to handle a full disk better than ReiserFS, at least so far. We do know ReiserFS can sometimes have difficulty when too full. "Personally", I like to keep at least 50GB free, on any drive with any format.
As a disk gets filled up, it gets trickier to find suitable regions of unused space regardless of filesystem (although ReiserFS is notoriously bad). The time it takes is related to the proportion of the space free rather than the raw amount, hence the classical 10% rule of thumb.
This is of course way less of an issue with the typical archive scenario of many unRAID users (including me) where the disk is filled once and then mostly read from. I keep some space free in case things get written to the “wrong” drive due to split levels.