No, that is not possible (note though that the rule is about HTML common attributes and that other attributes like href, src, style, and event handlers are specifically excluded).
The reason that the rule exists is given in the same document you quote:
Except for alphanumeric characters, escape all characters with ASCII values less than 256 with the &#xHH; format (or a named entity if available) to prevent switching out of the attribute. The reason this rule is so broad is that developers frequently leave attributes unquoted. Properly quoted attributes can only be escaped with the corresponding quote. Unquoted attributes can be broken out of with many characters, including [space] % * + , - / ; < = > ^ and |.
The exclusion of non-common attributes is actually relevant in practice. Consider this for example:
<img src="no" onerror="alert('[some user input]')">
An attacker can perform an XSS attack via ');alert('1
if the single quotes are just HTML-encoded. The input would be transformed to ');alert('1
, which would be parsed by the HTML parser of the browser, which then passes it on - in decoded form - to the JavaScript engine.