The FM band already goes below 88.1; while it is rarely available for use, it is possible to use 87.9 (channel 200) for Class D FM stations...that includes grandfathered "class D's" as well as FM translators. The rules are very restrictive, mostly because of TV6, but there's also substantial distance requirements from the Canadian or Mexican borders, and you have to protect 88.1, 88.3 and 88.5 as per usual.
Currently there are only two licensed stations on 87.9 in the USA: KSFH in Mountain View, CA (San Francisco Bay Area), and K200AA in Sun Valley, NV (Reno area). With the demise of TV6 in most of the US, there probably will soon be some applications to move a few translators to 87.9, although I just checked and there's no such app's filed yet.