Oh really? So these rules that Red Plume linked are just in my head? Looks clearly written to me:
Yes. None of the things you've written in this thread are actually present in the rule, as written.
All that rule says is that an NCE licensee must have an educational mission and that any demerits against that organization by any governing bodies or accreditation bodies may be taken into consideration by the Commission. That paragraph is a callback to when NCE radio was essentially run by colleges, and as far as I can tell it hasn't been updated in several decades.
Notably, the rule does not say that an organization that is neither regulated by a department of education, nor subject to accreditation is ineligible to be an NCE licensee. Such a rule would eliminate a great many of the NCE broadcasters of today, ranging from the City of New York (WNYE), through several states (i.e. Georgia Public Broadcasting) to EMF.
The rule also does not say how much of the broadcast station's time must be dedicated to an "educational program." Nor does it state what sort of programs might count. Nor am I aware of any instances where the Commission has rejected an application for not being educational enough.
For example, here is the educational showing of an LPFM whose license was granted, in its entirety:
INCORPORATED IN INDIANA, APPLICANT IS A NOT FOR PROFIT CORPORATION LOCALLY BASED IN [Redacted] INDIANA. [Redacted], INC. INTENDS TO BRING TO THE AREA DIVERSE, EDUCATIONAL AND CULTURAL PROGRAMMING NOT CURRENTLY AVAILABLE HERE.
If they couldn't deny that, then they couldn't deny an application written by a bright 4th grader. This particular LPFM ran 1960s oldies music, with occasional public service announcements as of 2015. I have since moved, and am not familiar with their current operation.