Even in the most perverse scenario of a single cell update the load for a terminal is still bursty enough that it's not like the GPU doesn't enter some power saving states. Running intel_gpu_top in kytty with a 100ms update is at least suggestive, it never drops below 90% RC6 (even at 50ms, which is a completely uselessly fast update rate we're still in the high 80s). If you're updating faster than 100ms legitimately, it's probably video or animation that is updating a large percentage of the display area anyway. The overall time my terminal is doing some animation while on battery is low enough that in practice it just doesn't matter.
https://en.wikipedia.org/wiki/Amdahl%27s_law
The problem you're up against is that, maybe if this was optimized most people would get 2 or 3 (or even 10) more minutes on a 12 hour battery life or something. No one really cares. Maybe they should, but they don't. And there's plenty of other suck in their power budget.
You make it sound like a binary power saving scenario, but it tends to be more nuanced in practice.
Most people run their terminal opaque, most display systems optimize this common case.
> Also, if you do damage tracking, make sure to report it to the display server
I'm not unsympathetic to your point of view. But I am skeptical that the power savings for most use cases ends up being much of a big deal in practice for most people (even accepting there may be some annoying edge cases that annoy some). I am interested in this topic, but I am still awaiting an example of a GPU accelerated terminal emulator that works this way to even make a real world comparison.