Len, I agree with everything you said....except: instead of migrating to HD subs, AM stations with severe HD adjacent-channel interference should be given a range of options, which could include:
(a) AMs with demonstrated interference problems can be granted priority for the equivalent of LPFM facilities, (but commercial) or short-spaced Class A FMs with the caveat that they surrender their AM licenses, or
(b) AMs with interference problems will be permitted to migrate to the expanded band PLUS be able to apply for new FM translators (instead of being forced to buy pricey existing ones) or
(c) Any AM operator would be able to turn in their license in return for a generous federal tax credit, in the interest of ridding the band of marginal or disused AM stations.
Federal grants or low-cost subsidized loans should be available to such affected AM stations. Why not? Tens of millions of taxpayer dollars are going to fund HD conversions in public radio. The cost of relocating a relative handful of adversely-affected AMs would be pocket change compared with the dough that's being blown on HD for pubcasters. Relief for injured adjacent-channel stations should be part of the budget for rolling out Wonderful HD Radio, if it's The Second Coming a few parties continue to insist it is.
Putting AMs on FM subs doesn't make sense. Most of the stations operating with HD-FM are owned by the big groups. Why would they put their smaller competitors on their FM subchannels? Besides there are few radios, little prospect that's going to change soon, and no audience, so even if the Big Guys went along ( which is highly doubtful) it wouldn't help the AM broadcasters in any meaningful sense.
And as a footnote: the coverage for the HD subs is lousy. The subs on a local Class B here barely go 10 miles with reliable coverage. (Yeah, I know - "power increase coming for HD-FM digital, etc., etc." So at -14 dBc the HD-2/3 will go 15 miles instead of 10.....BFD.....)