That statement does not follow logically. It won't generate more heat just because its PSU is internal. You might say that PSU being internal, it would generate more heat inside the casing for example, but since we don't know how much heat either of these devices generate it could still theoretically be possible for xbone to generate more heat than PS4, even with its internal PSU.Probably for heat concerns,the PSU been internal will generate more heat.
Also, with PS3, the PSU sits downstream of the cooler for the main guts, and thus does not contribute to the heat load inside the box, and even though the PSU is cooled by pre-heated air, it still probably runs cooler than the external power brick of the 360 (and presumably, xbone) since you can't have (large) vents on a power brick, or objects could end up sticking into them, electrocuting people and pets alike. Chances are that PS4's PSU will also sit downstream of the main heatsink, so PSU waste heat would not be an issue in that case either.