Power efficiency is important pretty much all the time in this day and age. If you look google for "M2 Ultra thermal throttling" there are plenty of examples. Everything is a balancing act / tradeoff, but I don't see how literally zero e-cores makes any sense from what we know today. Just on the basis of computers spending most of their time idling, you'd want at LEAST two.
For low-stress workloads, you could have the active performance cores clock themselves down and the inactive cores be at idle to minimize the thermal envelope.
If Apple adds efficiency cores to the M3 ULTRA, then they would use one four-core cluster (as found on the M3 and M3 MAX).
I have not seen the die shots, but presuming the performance cores are arranged in six-core clusters (one for the M3 PRO and two for the M3 MAX), I would expect Apple to offer a four and six cluster option, allowing for 24 or 36 pCores. And the "M3 EXTREME", if it exists, could offer eight or more clusters (for 48+ pCores).