It is very irresponsible to make statements like that. It is very common to have an attack, where the attacker gains access via social engineering to a server, and manages to restart the server and gain access to a rescue system.
And even then, nowadays renting servers is very common - how do you know you can trust everyone in the hosting company? FDE should be the default thing to do, especially for servers. I don't really understand why they aren't a standard practice already.