The thing is, the only realistic time to size the first partition is before Windows is installed.
And off-the shelf Windows PCs having UEFI/GPT layout started out using too small a FAT32 volume for the ESP boot volume, and have stayed that way far too long.
That was a good time to experiment with "full-size" FAT32 boot volumes, so I pretty much settled on 32GB size since that was the default maximum FAT32 size for so long since the 1990s, and even DOS 6.2 can access the volume if it is in MBR layout on a BIOS or CSM-enabled UEFI motherboard.
I figured if you want to try a bigger FAT32 volume for partition 1, you really need to do it on a new or blank HDD or SSD anyway, so might as well go all the way to 32GB.
Turned out to be a pretty good place for some Linux kernels too once you have the space. Also you can copy & paste them into their FAT32 folders using Windows which is pretty convenient. Plus some superb distros now put all their boot files in the FAT32 ESP volume (no longer storing them on the main EXT system volume for later virtual mounting), and this is incredibly convenient for PCs that are primarily Windows machines who want to experience about the most convenient dual-booting to Linux.
Interestingly, one of the automatic "upgrades" in the last couple of 2026 sessions is the feature extension of FAT32 partitioning in Windows 11 to no longer be limited to 32GB in size, if you use the command line instead of the GUI to do the partitioning & formatting. You can have up to 2TB in a FAT32 volume now.
This extension of FAT32 could very well fit better in the EEE category, when you look at it as perhaps most effective at producing volumes which are potentially more incompatible than ever with everything that came before. Which might turn out to be a more significant long-term effect rather than overall utility to users.
No telling if the latest FAT32 will now handle individual files over 4GB in size or if this form of FAT32 now has patents that have not fully expired. Will probably find out before too long.