Havoc if your claiming that universal overcharges during off season you can’t use peak pricing $100/15=7 rides. I’ve never visited UO when Spider-Man, Hulk, The three Potter rides, Despicable Me, Rip Ride Rockit and Mummy weren’t significantly shorter then standby.
I just looked up some low crowd days on TP's historical calendar for Universal...
Including a day I was there in February 2019... Only 6 Express Pass attractions had average standby waits of over 15 minutes. (that's average, so there were times of day when they were higher, but in the morning and evening, they were walk-on). On 2 attractions over 25 minutes.
Only attractions that were over 15 minutes:
Fearfall (18 minutes)
ET (25 minutes)
Gringotts (25 minutes)
Rip Ride Rocket (21 minutes)
Only rides over 25 minutes:
Despicable Me (33 minutes, but I did it as a walk-on in the morning)
Hippogriff (37 minutes)
So yes, on this fairly low crowd day -- The Express Pass is much more expensive than Disney's DPA, as it really would give very little value.
I mean, if I give a choice between a 25 minute line for Gringotts, or pay $15 -- I'd just take the 25 minute line.
On busy days when lines are long and Express Pass would be valuable, as you know, they charge over $300 for it. So even if you used it for 10 rides, that's still $30 per ride -- Much more expensive than Disney's Paris system.