Glen, I think that KDWN continues to exist as an HD-2 "primary" on one of the major FM stations, and the FM is merely translating that.  That's apparently legal, because I've heard at least one that was doing that.
A few years ago I heard a Bonner Springs KS translator on 102.5 as "Comedy 102.5" - and their legal ID as the HD-2 for, I think, the 94.9 biggie.  So, yes, they can translate an HD subchannel, and in effect the translator is the "primary" but they're allowed to run it as a translator.
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