Certainly not unable, but lots of factors seem like they would add to difficulty particularly if emulators didn't exist (because cartridge-based storage, aging/costly hardware). Then there's the idea of having a target on your back (or any tools that make it more viable) due to extremely litigious/malicious entities and to me it just seems like a niche that isn't worth the extra time.
I'm grateful for PC games under 100MiB. Closer to 10MiB is worthy of praise and below that may be half amazing. There is .kkrieger at only 95KiB for a 3D game (and that is another mealtime topic), but I think that is more interesting visually than it is for gameplay.
Or to be clear, I see the "STILL" more for creating games for old proprietary hardware than for optimization itself.