Just chiming in, first post ran across this site from google. Hi All!
Below is a paragraph from the Atmos specification for commercial theaters. True that surround speakers are not "required" to go as low as 20Hz but they do specify 40Hz, they also call it "full-range". That said, I don't think the human ear can tell what direction anything below 80Hz is coming from anyway. But all of my surround speakers as well as the two ceiling speakers have a 8" driver, mid, and tweeter. So that's 8x 8" subs around my room, and the LFE is a 15" folded horn. I can say the eight 8's put out a decent amount of low end. So you are both correct..
It seems the spec is more of a suggestion, but does pretty much say surround channels can contain 40Hz.
4.6 Surround Sound Frequency Response: 40 Hz to 16 kHz, +3/–6 dB Dolby Atmos auditoriums must support playback of full-range surround signals. To meet this specification standard, cinema surround speakers with limited bass response require bass management. If bass management is used, the recommended surround speaker frequency response (+/-3 dB) is 90 Hz or lower. The required surround speaker frequency response is (+/-3 dB) at < 130 Hz. The crossover frequency should be set based on the capabilities of the surround speakers, but must not be higher than 130 Hz.