It is clearly stated in html4.01 rec that at least one 
option element is required in a select element...

However these days option elements can be added dynamically
thru scripts.  What if one wanted to create a blank list whose
elements were to be added later as in my example at

http://home.cogeco.ca/~ve3ll/jstutor4.htm#dy 

This page will not verify using the current spec.  Should your
recommendations limit the use of dynamic scripting ???
Was this just an unanticipated case....
Of course a workaround is to force a blank option,
and first insert to list, overwrite rather than adding to list.
But that is crude compared to tolerating a blank list in the
first place .....  

--
john russell ve3ll@rac.ca [those are L's as in LLAMA]
http://home.cogeco.ca/~ve3ll 
http://home.cogeco.ca/~trains 
http://home.cogeco.ca/~cipher