Depends heavily on the GPU and the scene being rendered. On Android I've seen low-end GPUs bottlenecked by the shader ALU of all things, even though the 2D renderer only produces trivial shaders. Turns out it's easier to whack off shader compute cores than it is to muck with the memory bus in some cases.

Most common situation is the GPU isn't taxed at all, though, and doesn't even leave idle clocks. We end up just being limited by GL draw call overhead.

You seem to be implying that rendering of a text editor has to be all 2d and that rendering a frame pushes the memory bandwidth to it's limits, both of which can't possibly be true. Why can games run at 144hz and above but a text editor can't afford to overdraw for decreased latency?