Industry awaits FCC’s CALM rules
Nov 28, 2011 12:04 PM, By Michael Grotticelli
The CALM Act is intended to ensure a consistent audio level across the spectrum of TV channels (and in between programs) in the U.S.
While the industry anxiously waits, the FCC is scheduled to release its new rules governing loudness for broadcast and pay television by the end of December. Then, under the Commercial Advertisement Loudness Mitigation (CALM) Act passed by Congress in December 2010, broadcasters will have one year to comply with those rules before enforcement begins.
While the exact rules still aren’t known (to the frustration of broadcasters, audio professionals and related technology suppliers alike), broadcast industry experts are hoping that the FCC will be gentle with television stations when it comes to enforcement — understanding that much of the loudness issue is subjective and open to interpretation by individual operators. On the other hand, there is a similar expectation that the FCC will fine video distribution players of all types that intentionally air audio content that is clearly too loud.
At a number of public events throughout the year, FCC reps have unofficially said that stations could be fined as much as $10,000 for the first infraction and that the final distributor (cable, satellite, Telco and terrestrial networks) will be held accountable — not the original program producer.
The CALM Act requires the FCC to regulate the audio of TV commercials from being broadcast at louder sound volumes than the TV program material they accompany. It directs the FCC to establish regulations requiring TV stations, cable operators, satellite TV providers or other multichannel content distributors to follow the Advanced Television Systems Committee’s (ATSC) A/85 Recommended Practice (ATSC A/85 RP) to transmit commercial advertisements.
The ATSC A/85 RP standard, which is fully compatible with the ITU’s BS.1770 specs — which European broadcasters will have to adhere to — defines a set of methods to measure and control the audio levels (loudness) of commercials and programming in the digital domain. The FCC is currently converting what is essentially a 76-page recommended practice into a set of enforceable rules. While the rules are due by Dec. 15, there is still a lot of information about implementation and enforcement that has yet to be worked out.
At the recent Audio Engineering Society conference in New York City, Dr. Richard Cabot, chief technical officer at Qualis Audio, said that correcting problems is not as simple as watching an audio meter. Because loudness is a subjective phenomenon, he said, human hearing is the best judge of loudness. Early loudness measurements were made in listening tests by comparing the subjective loudness of a variety of program material. Algorithms were created from those measurements.
“The problem is humans can perceive sound level for a period of a few seconds,” Cabot said. “When grandma comes into the family room and hears the TV blaring, it takes her about three seconds to shout, ‘Turn it down. It’s too loud.’ Or, ‘I can’t hear it. I can’t understand it. Turn it up.’ It’s about a three- to 10-second window.”
Later research, which led to the creation of the ITU BS.1770-2 loudness measurement level (and upon which the FCC’s rules will be based), uses a process called “gating” for measurement. It measures the entire piece of content — in 10 microsecond chunks — and then uses a mathematical equation to assign the program a number.
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