However, how does that relate to using a shortend antenna with maybe
10% radiation efficientcy to a dipole at a reasonably attainable
height?

Well....Exactly as he described.
An antenna which radiates its maximum at a high angle might well
radiate more at a low angle than an antenna with a lower angle of
maximum radiation.

The thing is "might".... My mobile antenna on 40m is *much* less
efficient than my dipole at 40 ft. But...It still is the best to longer
hauls over about 800 miles, and to dx. In it's case, it does radiate
more at the lower angles I'm using at that time, vs the dipole.
With some lesser mobiles, "mine is fairly stout", this might not be
the case. The best antenna should always be decided to fit the
usual paths to be used. In the case of my mobile vs the dipole, it's
possible that if the dipole were raised another 1/4 wave higher, it
could match the mobile at those lower angles.
At home, I often ran a dipole at 40 ft vs a full size ground plane at
the same height. Both were pretty efficient. Efficiency comparisons
were fairly useless as to actual performance. What really decides
which is best at a given time, is the path, and angles to be used.
Now, if you compare two same length low dipoles, both to NVIS, both
shooting straight up, and one is less lossy than the other as far as
feeding method, etc, then yes, efficiency will decide which one is
best.
MK