Oven Spring when first stage of recipe includes a ten hour first rise
Generally when you have issues regarding oven spring at home, the problem is heat and steam in your oven rather than yeast activity. In commercial bakeries, sourdoughs are frequently fermented for overnight or longer, so that shouldn't be a problem. A lot of the expansion you see in the oven is from the moisture in your dough converting to steam before the crust has set. In a bakery, we can achieve this by using steam injected ovens which allow the crust to remain elastic longer. Bakeries also use hearth and convection ovens which transfer heat into the loaf more efficiently causing it to create steam faster. 

To recreate this at home, you can try moistening the crust of your bread before baking it or trying to create steam in your oven. You can encourage steam by starting your oven at a higher temperature and turning it down after a few minutes, or by baking on a pizza stone to simulate a hearth. It's important to get the steam down first though, as the heat transfer without steam will cause a lot of crust cracking and weird rising.

It's also important to note that if your dough has a high proportion of rye flour, rye traps bubbles via gums called pentosans rather than via a gluten network like wheat dough. It generally won't rise in the same way that wheat doughs will.