As I mentioned in my previous blog post Apple Passwords is hostile to backups, macOS 15 Sequoia removed New Secure Note Item from the File menu in Keychain Access app. My suggested workaround was to create a new password item rather than a new secure note, putting the secure note in the Password field and a dummy value in the Account Name field. A follower of mine on Mastodon noted (pun intended) that a secure note could still be created on Sequoia by using the security command-line utility:
security add-generic-password -a dummy -C note -D "secure note" -T "" -s your note name
You can read an explanation of the arguments in the man page of security. For some reason, the -a account argument is required, even though secure notes created in macOS Sonoma and earlier have no account. If no keychain is specified on the command line, then the secure note is added to the default keychain, which would typically be your login keychain. The empty -T "" argument prevents the security tool from automatically appearing in the Access Control list, which is probably not what you want.
security add-generic-password -a dummy -C note -D "secure note" -s Testing

Since it's still possible to create a new secure note in Terminal, the removal of New Secure Note Item from Keychain Access was clearly a decision hostile to Mac users, making the user interface more difficult than necessary. At best, it was paternalism; at worst, pure spite.
I would recommend adding a function to your .zshrc file. For example:
securenote() {
if [[ -z $@ ]]; then
echo "Note name required"
else
security add-generic-password -a dummy -C note -D "secure note" -T "" -s $@
fi
}