I've seen as low as 24GPD. Most (all?) RO\DI units you will find on reef supply sites use the same physically sized RO membrane (TW30-1812-xx
Aquarium Water | Reverse Osmosis | RODI Water | ReefKeeper Water | Membrane). This means if you buy a 50GPD system you can replace the membrane with a 75GPD membrane down the road. The only differences I have found are that the 100GPD membrane has a lower rejection rate (90% vs 97%) and the 150GPD membrane requires higher input pressure.
It just depends on how fast you need to make water.
I started out with a 50GPD RO\DI MightyMite unit. I also didn't have room in the apartment where I could keep my water storage containers and RO\DI unit hooked on a float switch full time. Every weekend I would hook up my RO\DI unit in the bathroom and make 20 gallons of water. Half would go to the a water change and the other half was my top-off water for the week.
Making water on demand with the 50GPD was a painfully slow all day process for me. The water pressure in my apartment was a bit low to begin with and the system was MAYBE making 2 gallons an hour if I was lucky.
Slowly over the past few years I have been upgrading my RO system. First I bought a booster pump, then swapped the 50GPD membrane with a 150 GPD membrane. Finally I ordered a new 150 GPD RO\DI system from Bulk Reef Supply and attached my existing 150GPD membrane and booster pump. (I had to buy a new system vs just an additional membrane and housing because the mighty might came with small self contained carbon and DI filter canisters. I wanted the larger standard type with the replacable elements like you see on most systems.)
Even though I am no longer living in the apartment I still make water on demand. With dual 150gpd membranes and the booster pump making water is much less painful. One additional benefit is that running two membranes at higher pressure also results in less waste water. One drawback is that when I am careless epic floods also strike quicker.
So thats my justification of why someone might want a higher GPD unit. If I had my RO\DI unit hooked up and running full time a 50GPD system would probably serve my needs just fine.