I don't think spectrum is an issue. For example KRCB
DTV channel 22.3 shows a "card" saying "You are listening to KRCB Radio 91." and the FM station is simulcast on that sub-channel. Since most serious FM listeners probably connect their TVs to decent amps and speakers anyway, why not extend the "listening" environment to the
DTV spectrum. In fact, you could use a converter box and a very small "handheld" TV propped up on top. And what about low power licenses for that very purpose?