I agree with Richard Stiennon
I think you are missing the point by attacking the example. I believe that Richard presented the fact that Windows is implemented in a less modular, more complex way, with a lot of interdependencies (sometimes no so obvious). This is a fact accepted even by Windows development teams who are working in documenting the interdependencies and streaming the code to make it more modular.
In Richard's opinion (and I agree) that complex code opens more opportunities for hackers to try for vulnerabilities, and make it more difficult for the developers to test against possible attacks.
The complex code can be a result of more capabilities supported or caused by the historic evolution of Windows, it does not matter, the fact is that Windows is implemented in a more complex way.