There are many reasons to accommodate non-JS users beyond accommodating people who have intentionally disabled it, and most of them are in accessibility territory.
Be careful with using percentages for your arguments, because this is not that different from saying that 99.99% of people don't need wheelchair access.
This used to be true, but now I don't think it is anymore. Modern frameworks and modern screen readers have no issue with acessibility.
Some survey from WebAIM found that 99.3% of screen reader users have JavaScript enabled.
So... are they really in accessibility territory still? Only people I still see complaining about Javascript being required are people that insist the web should just be static documents with hyperlinks like it was in the early 90s.
Can you find a modern source with valid reasons for accomodating non-JS users?
Slow/lossy connections: JS may not load, but site still works.
Users that prefer non-animated pages and disable JS for this reason.
Users who prioritize security.
Users of older devices in which your JS can trigger errors. Yes, these exist. Not everyone can upgrade their older device. Many people do not even have their own device to use.
Be careful with using percentages for your arguments, because this is not that different from saying that 99.99% of people don't need wheelchair access.