By Michael Grotticelli
November 28, 2011 - While the US broadcast 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.
“That new number is assigned to the content as the average loudness of the content,” Cabot said. “What that does is it throws away the soft parts of the program or commercial, and it focuses on the louder parts. This way, a dramatic program will line up with a late-night used car commercial in a way that is less objectionable to the viewer.”
The problem, Cabot said, is that it represents the loudness of the loud parts.
“If the dynamic range of the content gets too wide and the environment you’re listening in has too much background noise — say, in a crowded city with a lot of vehicle noise outside — then you have a dynamic range problem on your content,” he said. “If your dramatic material gets too soft, then you won’t be able to hear the soft parts, but that’s going to happen no matter what you do for setting the overall loudness of the content. So it’s about lining up pieces of content and commercials that play well with each other.”
A number of tests have been successfully conducted using the ATSC A/85 RP standard at all of the major networks facilities, and the industry appears ready. Companies like Cobalt Digital, Dorrough, Dolby Labs, Evertz, Harris, Linear Acoustic, Miranda Technologies, Nugen Audio, TC Electronic, Tektronix, Volicon, Wohler and others are eagerly awaiting a spike in sale once the rules are established (both for the U.S. and overseas). They supply the software (and hardware) required to monitor and adjust audio signals accordingly — in order to help broadcasters comply with the new rules.
The challenge for multi-site networks is to maintain a consistent level across a wide landscape and then ensure it gets delivered that way to consumers’ homes. Robert Seidel, vice president of engineering and advanced technology at CBS, said he expects his network to create a certification process to meet the new FCC loudness requirements. Seidel said the network “will certify to our affiliates that we are in compliance.”
The hope is that they, in turn, will assure the cable systems that they are in compliance, and the cable systems will also certify what they are doing.
“Certifying means you have purchased the equipment, you have calibrated and maintained the equipment, and are actively trying to control it,” Seidel said. “When a complaint occurs, it would have to be made up of numerous complaints. The FCC would then send a notice to the station asking their cooperation in verifying it.”
Seidel said he is not sure yet how long viewers will have to file a loudness complaint or exactly how broadcasters would go back and reconstruct what happened. He noted that some systems, like DirecTV, don’t use metadata and can just use the loudness measurements obtained from BS.1770.
“There are a number of issues we are still waiting to learn from the FCC,” he said.