Like what situation? To build an app at all he requires at least one computer, which is guaranteed to cost more than $99. He didn't blink at paying $25 to access MacInCloud.
The $99 fee is hardly a big deal. It's quite clearly there to encourage people to report charges on stolen credit cards, i.e. to make credit cards usable as a form of ID verification.
You're excluding people and organizations who want to maintain a single codebase.
There are ways to do that which don't require the web.