Replying to myself: but 17 USC § 111.a.5 does apply and it's very specifically applies for "... other nonprofit organization, without any purpose of direct or i

Replying to myself: but 17 USC § 111.a.5 does apply and it's very specifically applies for "... other nonprofit organization, without any purpose of direct or indirect commercial advantage, and without charge to the recipients of the secondary transmission other than assessments necessary to defray the actual and reasonable costs of maintaining and operating the secondary transmission service."