E-Mail Creative: Is Text Replacing HTML?

There was a movement a few years ago (circa 2001 to 2005) to get rid of HTML emails and move to an all Text format for most all email marketing programs.

A few of the arguments in favor of all text email were:

1. HTML may have deliverability issues.
2. HTML is time consuming to create.
3. Recipients may have images blocked.
4. HTML does not always render the same across email platforms and browsers.

Take a look at this ClickZ article for more on this argument in 2004.

Needless to say all text emails never caught on and replaced HTML.  HTML heavy emails are the norm in most email marketing endeavors and the four arguments above have not been email format killers.  Alternative text helps solve the blocked image issue and displaying a rich text version helps for devices that do not render HTML.  But recently I have seen more and more almost all text emails.

Here is a recent example from Old Navy. Old Navy generally sends HTML heavy email. In this case everything in the email is text except for the small logo at the top.

Will sending text heavy emails be a  new trend?  
Why is this occurring?  What is the benefit?
Will the HTML vs. Text email argument rear its head again? 
Let us know what you think!