The particle system has camera orientation modes, these are FacingCamera, FacingCameraaWorldUp, VelocityParallel and VelocityPerpendicular.
The issue happens only on the FacingCamera orientation mode,
This video will detail the issue;
Notes on the video;
I don’t believe this is a rendering optimisation thing, because the particles are not DE spawned, there just made transparent, and have a clear de-spawn point that is the same as every other particle render type.
And from what I read, partially transparent objects (though minorly) use more performance then fully opaque objects.
While researching if this issue has been reported before, (it has not, or at least not to this certain point), similar issues came up to do with particles getting closer to the ground and gaining transparency due to the soft particles update back in 2016 (Soft particles live on prod)
So It might be related to that.