I would guess this would be a point to be raised by the CAA and our representative bodies.
The history of Ofcom's consultations shows they pay lip service to the idea of safety.
The maritime one looks at exempting (or giving a discounted rate) to charitable and life-saving organisations, such as the RNLI.
What they don't see is the need for even small airfields to have a frequency (often shared between a number of airfields anyway) so that we can get the information we need about traffic and weather.
That part of the case I would guess will be very lightweight against the very real financial benefits of selling off the spectrum.