I guess that depends on where you're comfortable "sitting," ie your setpoint. If you're a guy who can, without thinking, maintain at 8-10%, then I'd say you'd generally want to be leaner because to get lean won't require effort to the point that you lose muscle.
But if you're naturally pudgy, I'd shift the range higher because you'll more muscle with the fat when cutting at low BF ranges. So it's basically related to how much your body likes fat and won't let go of it when cutting.