This does not look good for us...

[mossy]

I've skimmed through it.

The assumption in all this is that the Moon is a non commercial station. Yes?

That said, and according to my understanding:

Non commercial webcasters are allowed an allowance of 159,140 Aggregate Tuning Hours per month before the "per tune" fees will kick in. If a station keeps below the 159,140 ACH allowed per month, the fee will be a flat $500 per year.

See page 58 of the document to see how to calculate ACH. I calculated 100 average US listeners to yield 73,000 ACH, well below their limit. I'm not sure if I'm understanding ACH completely though, or calculating correctly so perhaps someone else could also take a look.

See also page 61, 102 for more on ACH, and 106 as a synopsis.