I don't know how much of this is encroaching upon super secret territory so I'm going to be as vague as possible while still trying to get my point across.
There exists a method by which you can actively lower your DO once per day. This ability is gated behind 100th circle.
I think you should be permitted to use this DO lowering ability as soon as you become Forsaken. It does not make any sense to me for it to require you to be 100th+ circle, since Lichdom and Transcendence are slated to become available at 100th circle, and at that point you won't need to use the DO lowering ability because you'll be immune to DO.
If making it available as soon as you go Forsaken is not feasible then, then taking 30-50 circles off of the requirement would still go a long way toward making it more usable now, and especially in a post Lichdom/Transcendence world.