Earlier quoted context omitted.
What does it actually mean to create a distro though? Is it just what software you package in your flavour of debian?
To be an independent distro it should at least have its own package manager.
It's an interesting question though, that I haven't thought about. At a minimum I'd say that it should have some sort of coherent goals and philosophy, its own package repository, and should not be replicable from its parent distro with a script to install/remove various packages.
The last one is probably the most critical, if it can do something the base distro can't, then it at least has a reason to exist, whether or not you want to call it a "distro" or not.