Clause 5 explanation says
However, the subscriber, as per his requirement, shall have
complete freedom to choose either bouquet of basic service tier or any other bouquet of pay
channels or any other bouquet of free-to-air channels or a-la-carte pay channels or a-la-carte
free-to-air channels available on the platform of the distributor of television channels or a
combination thereof
So Dpo can definitely form basepack with only pay chs without FTA chs. No need to subscribe 100 FTA chs if someone don't want