A couple things about Boulder's observations. Listeners who are experiencing interference are not expected by the FCC, to have a copy of Parts 73, 74 and 22 of the CFR on their laps when they file complaints. I never alleged that all FCC complaints "must" reference a specific rule being violated. I simply said that all complaints involving IBOC stations bothering desired local stations should be reported to the FCC. The FCC does not require complainants to meet a "burden of proof" nor are members of the public expected to file complaints in the format of formal pleadings or petitions.
Naturally I encourage all stations experiencing serious IBOC interference to get together with their consulting engineer and communications attorney to prepare formal complaints, whose formats would be more likely to please Boulder than lowly letters from actual radio listeners.
SPECIAL NOTE TO ALL BROADCASTERS: If you suspect that an IBOC skywave signal is likely to start interfering with you at night starting September 14, you would be well-advised to get out there THIS WEEK and aircheck your signal at a variety of points within your NIF, your 5mv and 2mv contours. In this way you'll have a baseline for real-world receiving conditions, a "before" if you will, so your consultant can revisit those spots with an FIM and a spectrum analyzer once the IBOC skywave starts arriving. Check with your consulting engineer for the best way to do this with your station.
Boulder, thanks for reminding me. Addressing listeners once again: if you're going to complain about IBOC interference, be sure to complain emphatically to the GENERAL MANAGER and SALES MANAGER of the affected stations. Remember that the "solar plexus" of every radio station is SALES, e.g., "the revenue stream." The express-lane to shutting off the IBOC exciter leads through the front office, where interest in HD-AM will expire quickly if it starts to cost money and management preoccupation. It's probably a waste of time to complain to the Chief Engineer, who likely was told to shut up, hold still and "just install the thing" against his/her better judgment.