The difference I see is that this author isn't asking for anything more than a little bit of useful static text. No meaningful code changes, just a tiny snippet of plain old HTML will do the trick.
That's dramatically easier than trying to make a complex app work in IE6.
I agree. The article itself is correct, but if you read through the comments here, you'll find it often gets to be about purity and how entire applications should be written to degrade gracefully. When you start talking about that kind of work – I have to ask what the difference is between coding an entire app for no JS and IE6. You can chalk it up to good for humanity, but really it comes down to is time. Am I going to count of JS being on? Am I going to count on the user not using IE6? For a full-featured web application: Yes.
Every site would have the same exact text. "Please enable JavaScript because we don't want to develop a second version of our site for an extremely small constituency".
That's dramatically easier than trying to make a complex app work in IE6.