I do not think this is the right way. The right way would be for Apple to allow for a free Developer ID for distribution if the app is free and has no in-app purchases.
This provides IMO all-around goodwill while still adhering to good release practices.
Or maybe lower the price to $1.
_Some_ barrier of entry I think is needed (and intended) to stop everyone and their mother from creating developer accounts.
I don’t think Apple needs or cares about the $99