Magister Militum's approach to fantasy character packs seems a low cost method. For example their Goblin pack has a couple of wizards on foot (the same sculpt) and a mounted wizard, the rest are basic command figures, standard bearers and officer types from the infantry/cavalry packs. There's also one giant spider for a general or hero, with the figure coming from the mounted spider pack - so a basic figure repurposed as a character.
So to create a decent character pack for Dave's range, for example, he'd only have to commission a couple of wizards and perhaps a mounted general?
Of course, to get to that point, you need a decent number of basic command figures already sculpted. Without those, yes, it wouldn't be very viable.
Once you've got a range of figures, you might then consider selling individual ones, like Pendraken does. This would generate a few more sales. But how much of a drain on an individual's time that might be is another matter entirely!