What is the issue with the HTML Standard?

§ 13.1.2.4 (optional tags) states that

[…] a start tag must never be omitted if it has any attributes.

If this refers to an esoteric use case (any that come to my mind look like like they would be treated as text), it would be helpful to give a brief example and provide more detail.

If there’s no practical way to set attributes without a start tag (which it looks like), it seems this could be skipped? (Happy to file a PR.)