Broadcasters Await FCC CALM Rules

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.

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 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.

Dr. Luke Relies on DK-Technologies

Top Music Producer Chooses DK for Loudness Accuracy 

Dr. Luke

Los Angeles (November 4, 2011) – Lukasz Gottwald, known in the music industry as Dr. Luke, is the producer and sognwriter behind top hits by Kelly Clarkson, Ke$ha, Katy Perry, Britney Spears and many others. He’s heralded as one of the top producers working today and has recently chosen a DK-Technologies MSD600M++ Audio Meter for the critical function of monitoring his loudness, phase correlation and true peak levels in both stereo and surround sound. 

Luke performed with the Saturday Night Live Band for ten seasons until 2007. He has co-written and co-produced a string of highly successful songs and was named one of the top ten producers of the decade by Billboard in 2009, was awarded Producer of the Year and Songwriter of the Year awards in 2009 and won the Songwriter of the Year Award at the 2010 and 2011 American Society of Composers, Authors and Publishers (ASCAP) Pop Music Awards. Gottwald was also named both the Number One Hot 100 Songwriter of the Year and Number One Producer of the Year by Billboard.

DK-Technologies MSD600M++ Audio Meter

The MSD600M++ Dr. Luke chose is a modular, multi-channel audio analyser accepting up to 32 input channels. The meter has 4 configurable input slots and 4 output slots. Available modules include Analogue, AES3 and SD-SDI formats.

For mrore on the DK-Technologies MSD600M++, click here.

DK-Technologies Launches Revolutionary DK Meter

Danish manufacturer DK-Technologies uses the IBC platform to show the Award-winning DK Meter to European broadcasters and content producers.

Amsterdam, NL (September 7, 2011) - The groundbreaking Compact Audio Loudness Meter (CALM) was the subject of huge interest when it was unveiled in prototype at NAB in April, 2011. It will be shipping in November and is already generating orders from broadcasters looking for a reliable, high quality solution to their loudness metering requirements.

The DK Meter is truly revolutionary. No bigger than a smart phone, it is designed to meet increasing demands from the market for cost-effective stereo and 5.1 metering, including loudness. Two versions of the DK Meter are available: the DK1, which is ideal for anyone working in stereo, and the DK2, which is specifically aimed at the burgeoning 5.1 surround sound market.

The DK Meter is easy to use, easy to install and comes with its own desk-mount. It accepts digital audio inputs and is supplied with all known loudness measurement recommendations, as well as the standard DK-Technologies meter scales. Pricing for this product is highly competitive – under $1,500.00 in the US. 

Richard Kelley, Director of Sales and Marketing for DK-Technologies, says: “In light of the recent legislation on audio loudness, broadcasters have been crying out for cost- effective and easy to use metering technology that helps them keep within the guidelines. This latest addition to our range fits the bill perfectly. It draws on DK’s many years of experience in the audio metering market and addresses all of the issues broadcasters currently have with measuring loudness. What’s more, like all of the meters in our range, this new product can be easily updated to accommodate any new standards that might be introduced in the future.”

DK-Technologies will also be showing it full range of audio and video metering solutions including the DK PT0760 HD/SD waveform monitor, which features a new software upgrade allowing users to swap functionality between its various control buttons.

All of the audio meters in DK’s range are complaint with ATSC, EBU R128 and ITU BS1770/1771 Loudness recommendations, including the newly announced loudness range and relative gate recommendations from the ITU. Customers with existing MSD or PT0 600 series audio meters are being offered a free software update that will enable them to use the new Recommendations.

Alongside its focus on the important issue of loudness, DK-Technologies will also be showing a number of other new innovations including the PT0700R Client Panel - a remote unit for the award winning PT0760M HD/SD Multi-channel Video Waveform Monitor; the PT0740M, an audio-only version of the versatile PT0760M waveform monitor, and the popular PT5300 Compact VariTimeTM Sync Generator.

DK-Technologies can be found at IBC Stand 8:E60. If you would like a demonstration or more information about any of these products, please come and see us.

LIFT Distribution Opens with DK-Technologies

Seattle, WA (Sept 3, 2011) - A new US professional audio and video distributor, called LIFT Distribution LLC, has just opened its doors for business in the town of Kirkland, WA – an eastern suburb of Seattle. The new company, which will specialize in broadcast and live performance technology, has been founded by LIFT AV owner, Steve Palermo, and Audio Agent/3dB Creative founder, Dave Christenson. 

The Seattle-based LIFT crew (L-R: Christenson, Palermo, Ellis, Friesen, Mittleider)

“With LIFT AV, we’ve been extremely successful as a Pacific Northwest dealer and systems design/install company,” explained Palermo. “Moving into a national distribution role was a natural next step and, frankly, one that was heavily encouraged by some of our LIFT AV vendors.” LIFT Distribution will anchor its broadcast division with the DK Technologies brand and its live performance division with the KV2 Audio brand. Other select brands will be announced shortly. 

Richard Kelley, DK-Technologies’ Sales & Marketing Director, commented, “As a proactive company with excellent credentials in the broadcast market, LIFT AV and now LIFT Distribution, is ideally placed to strengthen our US sales channels and introduce many new customers to DK’s outstanding range of audio and video metering products.

Our new DK Meter. especially, is well suited to the US market because it meets the needs of broadcasters and production houses who have been crying out for cost-effective, easy to use metering technology that helps them keep within the new CALM Act guidelines. This latest addition to our range draws on DK’s many years of experience in the audio metering market and addresses all of the issues broadcasters currently have with measuring loudness. What’s more, like all of the meters in our range, this new product can be easily updated to accommodate any new standards that might be introduced in the future.”

“LIFT Distribution will be utilizing a unique web-based business model that combines unilateral pricing policies, direct sales, a highly exclusive US dealer network and superior customer support to become a true value-added partner for our vendors and customers alike,” added LIFT’s Dave Christenson. 


DK-Technologies Helps Dramatico Stay Legal

Harlev, Denmark (August 15, 2011) – DK-Technologies has supplied Dramatico Entertainment Ltd, the UK record label set up in the early-1990′s by singer/songwriter/producer/arranger Mike Batt, with an MSD100C loudness meter. Dramatico’s stable of artists incudes the current French “First Lady,” Carla Bruni (below), Marianne Faithful and a wide range of international recording stars. The label is using the ’100C meter to ensure that all its television advertising and promotional campaigns fall within the legal limits for loudness consistency. DK-Technologies’ range of audio metering products are all complaint with the latest loudness recommendations, including ITU 1770-2, EBU R128 and ATSC A85.

Dramatico invested in a DK MSD100C Loudness meter in order to ensure that it stayed within BCAP guidelines on audio loudness for TV commercials. The label, which achieved its first resounding success in 2003 with the phenomenal Georgian singer-songwriter Katie Melua, has its own recording studio, from which it also controls the audio output of all of its television advertising. Andy Page, DK’s UK Director, recommended the MSD100C Loudness meter as it was specifically designed for monitoring audio loudness, “There are many applications where it is necessary to measure and control the perceived loudness of audio signals, but when you are producing commercials that are destined for output via major broadcasters you really have to stay within the recommended BCAP guidelines for loudness or you could incur a fine. DK’s MSD100C Loudness meter is the ideal tool to help broadcasters stay within the law because it tackles the issue of the perceived loudness of the audio signal.”

Developed in response to requests from top broadcasters and production houses worldwide, including Sky, ITV, the BBC and RAI in Italy, the MSD100C Loudness incorporates ATSC, EBU R128 and ITU Loudness Recommendations and provides accurate loudness matching of audio from a number of different sources. It is ideal for any broadcast or post production facility that wants to measure loudness during production or prior to transmission.”

CALM Act: Facts and How to Protect Yourself

September 27, 2011

The Following are FAQ’s relating to the practical effects of the recently passed CALM Act. 

The Commercial Advertisement Loudness Mitigation Act (H.R. 1084/S. 2847) (CALM Act) is legislation introduced by United States Senator Roger Wicker, a member of theUnited States Senate Committee on Commerce, Science and Transportation, on June 18, 2008.[1] It requires the Federal Communications Commission to regulate the audio of TV commercials from being broadcast at louder sound volumes than the TV program material they accompany.[2] The bill passed on September 29, 2010.[3] The bill requires the use of technology to ensure that commercials will be played at the same volume as the program. The U.S. Federal Communications Commission (FCC) will begin enforcing this bill within a year.[4]

The bill was the United States Senate companion to proposed legislation in the House of Representatives by Representative Anna Eshoo, a member of the Energy and Commerce Committee. The House bill has passed the Communications Subcommittee. Most of the bill consists of steps taken voluntarily by the broadcast industry and approved as “recommended practice” by the Advanced Television Systems Committee (ATSC) on November 4, 2009.[5] In fact, Rep. Anna Eshoo (D-Calif) told the Wall Street Journal that legislation to mitigate the volume of commercials on TV was among the most popular pieces of legislation she’s sponsored in her 18 years in Congress.

Prior to adjourning for the midterm recess, the United States Senate unanimously passed the bill on Thursday, September 30, 2010.[6] Before it was signed into law by the Presidentin December, minor differences between the two versions had to be worked out when Congress returned to Washington after the November 2 election.[7] The reconciled bill was signed into law by President Barack Obama on December 15, 2010 as Public Law 111-311.[8]

Frequently Asked Questions:

Q: Is there a technical basis for the CALM Act?

A: The CALM Act refers directly to ATSC Recommended Practice A/85 “Techniques for Establishing and Maintaining Audio Loudness for Digital Television”, available for download free of charge at:

Q: What does a station have to do to ensure compliance?

A: The CALM act compels the FCC to enforce rules that have been the law for over a decade, namely that average integrated loudness of the station audio match the dialnorm metadata parameter in their transmitted Dolby® Digital (AC-3) stream.

Q: Does this mean that the audio must equal the dialnorm value constantly every second? 

A: No. If dialnorm is set to -24, the audio should measure 24LKFS on average, integrated over time. The precise time has not been established by the ATSC yet, but a useful range would be 10- 30 second integration. Some instantaneous variance is OK and expected – this simply means your audio has dynamics and this is a good thing. The key is that it should be correct on average. Q: Does the dialnorm value have to be -24? A: No. The dialnorm value can be any number between -31 (indicating very quiet audio) and -1 indicating very loud audio. The only rule is that dialnorm actually matches the measured loudness of the audio – or vice versa.

Q: How do I measure loudness?

A: A growing number of commercially available meters that support the ITU-R BS.1770 standard can do this. The DK Technologies PT0740 and PT0760 meters can display dialnorm provided they are fitted with their Dolby® Digital (AC-3) Decoder modules.

 Q: What if my station audio does not match the dialnorm value?

A: If it measures consistently at a given loudness value, simply re-adjust the dialnorm value to that number, or apply static gain or attenuation to the audio so it matches the dialnorm value.

Q: What if my station audio is sometimes too loud and sometimes too soft?

A: You may need to measure and fix each segment of audio separately. This may involve purchasing an ITU compliant meter and training staff to ingest material more consistently.

Q: Does this apply to my subchannels as well?

A: Yes, all transmitted channels must be compliant.