Reason: Many of my notes are "journals" on specific subjects. So new stuff is added at the top, rather than the foot - like an email list. So, I might insert a few carriage returns at the top of the page to push the current text down. If I'm then distracted with a different task, these blank lines can remain for some time.
A second reason follows from the first reason. About 10% of my notes consist only of a 1-line title - no text. For example:
- Brazil: 5 football pitches per minute burning
So, if I see a note with one blank line (Max = 1), then I'm not sure if it's an empty note, or a note with a few blank lines at the top.