Should the preferences window be excluded from the "Window" menu?

[sindresorhus]

I noticed that in some apps, the preferences window doesn't show up in the Window menu. But there's of course no consistency on this.

Apple Feedback Assistant report: feedback-assistant/reports#111

Shows in Window menu

• Xcode
• Calendar (but in a different list than the main window, which is just weird)
• Reminders
• Safari
• App Store
• Mail
• Contacts
• Photos (but with a separator between it and the main window)
• Keychain Access
• Script Editor
• Dictionary
• Pixelmator
• Fantastical
• BusyCal (but with a separator between it and the main window)
• Transmit
• 1Password

Does not

• Notes
• Messages
• Final Cut X
• Music
• TV
• TextEdit
• Grapher
• Terminal
• Preview
• Sketch

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Based on my findings, I'm leaning towards keeping it in the Window menu. But I'm looking for more opinions.