Couple of thoughts:
- Apart from emergency frequencies, which are free, the height of the fees only seem to be based on the Designated Operational Coverage. That's why a Tower frequency has the same fee as an AFIS or A/G frequency despite the vast difference in type and amount of traffic handled by these services. And anything that's got a DOC that's bigger than that, including things like ATIS and Volmet, get a ridiculously high charge. Doesn't seem fair, does it? This argument obviously works both ways: if you draw things to a logical conclusion then any small A/G station should be able to make a bid for the Heathrow Tower frequency.
- Ofcom seems to think that aviation makes money from these aero frequencies, just like cellphone providers make money from their frequencies. Based on this thinking, they try to apply basic economic principles of scarcity, supply and demand to the spectrum. But this premise is flawed: we don't make money from chatting to each other, we make money by moving stuff and people from one place to another. There are several points in the consultation that can easily be torn apart because of this alone.
- There is no mention whatsoever of "operator frequencies", while these are perhaps the only frequencies with a DOC that's big enough to matter, and where the economic principles of scarcity, supply and demand would work. Not to mention that within the context of a single operator, it would definitely be possible to give up the operator VHF frequency and replace it with a completely different technology (like UHF, cellphone, satphone, ACARS, ADS-B or whatever).