I disagree less with that than your previous assertion that orbital stations are deep space stations, but IMO you're still misunderstanding the question...
It may be that in common usage, “orbital station” refers to a space station within an atmosphere, but “orbital” has nothing against “deep space.” For example, the moon orbits the Earth. The Earth and moon orbit the sun. The Earth, moon, and sun orbit Sagittarius A*. These orbital bodies orbit other orbital bodies well outside of any known atmospheres. So, an orbital station does not technically refer to a space station within an atmosphere and could just as well refer to a deep space station that orbits a planet outside of the extent of its atmosphere.
I like to think of the history of the starbase like this,
I think that most of us have forgotten what a Federation starship was. It was a vehicle designed to transport people from one place to another place through space.
A primary motivation to go from one place to another place through space was to explore strange new worlds, to seek out new life and new civilizations, especially other warp capable peoples.
Normal people did not want to stay on a starship. They wanted the starship to take them to their destination and then they wanted to get off the starship and visit new places and people.
That is where starbases came in. They were the best destinations. Like ports or airports, starbases were gateways to the civilizations of entire planets and even solar systems. Even explorers could get tired of their work and hope to enjoy shoreleave through visiting a good starbase. Every warp capable civilization would see the advantages of constructing a number of starbases on their planets to host visitors. Along with the starbases, many would also construct a number of facilities such as nearby space stations in orbit to better serve visitors from space and their deep space vehicles that might stay in orbit. Even so, their best services were available to the people on the planet in the form of people to see.
So, who would conceive of the idea of building a starbase in the middle of space, like a gas station in the middle of a desert? At best, such facilities could offer only limited services and virtually nothing of interest to the people who might pass through out of refueling necessity.
While the technical terms, “orbital,” “space station,” “deep space,” “starbase,” are distinctly clear (to me), the common usage of these and similar terms is open to interpretation and has more to do with the people that use them than the facility itself.