The problem is, what it says is inaccurate compared to what I see WP actually doing. A styles.css containing only a comment, plus a set of completely empty *.php files results in that stub "theme" not being recognized as such by WP Dashboard. What am I supposed to think of this SILENT failure mode? (Not my definition of quality.)
If the WP community actively discourages development of themes from scratch, then the status quo in the WP release (i.e., providing no "minimal" set of theme file for beginning development from scratch) is the way to go. Otherwise, the installed WP package should include a set of minimal files ready for theme development from scratch, like every other development-ready software product in the world.
You don't want to know my opinion of WP's docs. I used to make a living writing software product documentation.