No. If see and avoid does not give an adequate level of risk reduction you put in class D or higher airspace.
ICAO has no radio requirement for VFR aircraft in E,F and G airspace because there is no way of knowing if the radio is actually working and on the correct frequency.
Pretty simple really. Sounds as if you are putting profits in front of safety if you do not support Class D where see and avoid is not adequate.
Or do you support airline pilots looking down at the TCAS screen in the terminal area rather than remaining vigilant and keeping a good lookout?