Both would apply. Then the geese flying-V. All benefits to wake turbulence, so there's a few in given situations.
Aren't there a few other principles/physics still working against single-engine (or multi) prop-driven aircraft that aren't for geese, making it more difficult or less effecient? IE: prop-wash torque/spin (or whatever that term is). I believe there's more to a plane's wake (physics-wise) than a gooses, if im not mistaken.
Obviously the geese benefit from drafting to some extent.
One thing I've found interesting is that when one of my birds overtakes a duck , pheasant, etc, it doesn't seem to be effected by turbulence to any level that I can detect. This applies both for falcons (which spend a fairly brief period, if at all, behind their quarry) and for accipiters, which get into some hair-raising, fast, tight-turning chases.
I would expect turbulence to be different simply due to the difference between propulsion methods of birds vs. aircraft. I also don't know of any planes that are quite as streamlined as a falcon (depending upon the birds flight configuration), although nothing is drafting off of them...