I see the point and it is interesting, it's just not big O ^^
If I replace in my head all O(thing) by MyCustomComplexityMeasureYetToBeDefinedProperly(thing) then it makes perfect sens.
Big O is basically that. Big O notation predates computers (late 19th/early 20th century) -- it's simply a notation to signify how a problem scales in complexity in relation to the size of the data set. I would argue that multi-level memory access is itself a problem that scales complexity in the same way.