As long as the tank has sufficient surface agitation from other sources, it doesn't need bubbles. However, tanks with an airline or venturi tubes to break the surface of the water are less prone to O2-deprivation problems that can occur if something big in the tank dies or if there is a sudden die-off of macroalgae. Powerheads pointed at the surface rarely help if a film forms there, since it just gets pushed around instead of actually broken. Even then, the extra surface chopping doesn't have to come from a noisy venturi tube - an open end of airline stashed away in the corner works fine and is much quieter. If you keep macro like Caulerpa or even some of the safer varieties like Halimeda, then as a safety precaution I would definitely put some bubbles in somewhere even if not with the venturi tube. Otherwise, it depends on whether you can point powerheads at the surface enough to provide the necessary agitation. The amount of agitation should be fine if the pH is staying within 8.0-8.4 at night and you can see a lot of ripples on the surface.