I don't think so. It makes zero sense. The ESRAM is a working buffer - you'd no more reserve a slice of it for the OS than you'd reserve a slice of L2 CPU cache.
From everything I've read, there is fairly fine grained control of buffers placed in esram, and in no way behaves like the L4 in Intel's GT3e. The OS would be oblivious in attempting to identify the best pages to move out if it wanted some of that ram for its functions and could kill all the game titles expected timings. The easy solution would be to reserve some, which is possibly what we are seeing/reading about here. But I don't know for sure. My suggestion is they could define a state in which the game title knows it would lose a certain portion of that memory so as not to have a constant reserve, but its implementation not ready for launch.
If there is a reserve it would be interesting to know what it is, what its used for, and how much of it Ghosts needs. I don't think they are deferred, and simply a straight z-prepass during which they do some light stuff. Back of the napkin math doesn't add up to needing to come all the way down to 720, so its very curious indeed.