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Well, yes - if you are using an encrypted rootfs on a server, the disk is permanently in an unlocked state - so it doesn't completely matter if encrypted or not.
It is very irresponsible to make statements like that. It is very common to have an attack, where the attacker gains access via social engineering to a server, and manages to restart the server and gain access to a rescue system.
And even then, nowadays renting servers is very common - how do you know you can trust everyone in the hosting company? FDE should be the default thing to do, especially for servers. I don't really understand why they aren't a standard practice already.