TV CALM Act

[jfrancispastirchak]

The country can't get its financial house in order, but congress is worried about the volume of commercials.

Hillarious, and I share your pain. To be fair though, today's fiscal cliff panic was only rhetoric when CALM legislation was created. CALM became law this month, but actually "passed" last year.

 

[jfrancispastirchak]

What we really need is a device that will mute the commercials automatically.Now that would be awesome!!Merry Christmas Everyone...

"The Hopper"

I hear ya, but trust me, the trade would lobby such a device into oblivion.

 

[gtomas]

Label the scale however you want for TV. In the end, you're still dealing with peak and average (loudness) audio.

It's not just labeling, it's the way of measuring...

I looked at TC Electronics TV gear. The word "peak" is mentioned many times over and over. Even though the CALM act makes you pay much closer attention to "Loudness", you will still always have a peak to go along with your average loudness level.

You will, but the peaks are not the focus any more, average loudness is. Peaks may fall wherever they want, as long as they don't go over -2 dBTP (true peak). With the target loudness level of -24 LkFS, that's almost 22 dB of headroom! If you use all that headroom, you will need only a tiny bit of protection limiting (if any) to prevent peaks from reaching that threshold.

So there are still going to be loud parts and quiet parts.

Of course... And they will hopefully be used for artistic intent.

But the over-processing will no longer gain you benefit in being louder, because it's not a peak world anymore. It's loudness based.

I don't see how the average joe is supposed to understand this.

He doesn't. Broadcast engineers do...


Regards
Goran Tomas

 

[WNTIRadio]

With the advent of digital TV, processing for loudness to overcome S/N ratio isn't the concern it used to be. Also, most new TV's have much better speakers than those sold 20 years ago. I did say "most", because I have run across a few flat panels that for $1,500 should sound as good as they look. Can only do so much with a 1" thick box.

 

[gtomas]

Loudness is far more complex than average/peak audio.
Many commercials are equalized to boost the region around 3kHz.
This makes the commercials sound louder because our ears are most sensitive to that frequency area.
There is no guaranteed 'fix' to the loudness problem until the commercial producers stop over-processing their products.

There's always way to "cheat" and increase the loudness, with any measurement...

That being said, the BS.1770 loudness measuring algorithm is based on research in subjective perceived loudness and as such, tries to mimic the way people hear loudness. The meters reflect this and so do the loudness regulations (such as A/85 and R128). No measurement is perfect and also people will always differ slightly about how loud (or louder in comparison) something is, but this is the best solution the industry came up with to solve the problem of varying loudness and loudness differences in TV broadcast.

Essentially, this is a TV industry's move from peak audio normalization and measurement, to loudness audio normalization and measurement. This picture tries to illustrate that:

http://www.interrasystems.com/images/wp_peak-loudness-normalization.jpg

If you have a bit of time (and don't mind the European perspective) a couple of these videos (part 1, 2 and 3) are worth watching. They explain the motivation, the goal, some caveats and means of achieving the uniform loudness in TV broadcast:

http://www.youtube.com/watch?v=6KSRnLhdUuI&feature=share&list=PLioeOOkGBUHR_Gq5pVa4OT2uffOdJRFEi


Regards,
Goran Tomas

 

[satech]

You will, but the peaks are not the focus any more, average loudness is. Peaks may fall wherever they want, as long as they don't go over -2 dBTP (true peak). With the target loudness level of -24 LkFS, that's almost 22 dB of headroom! If you use all that headroom, you will need only a tiny bit of protection limiting (if any) to prevent peaks from reaching that threshold.

Now if only the music industry was forced to abide by the same standard when releasing music on CDs and iTunes/MP3!

 

[jonbruce]

In Palm Springs the only full power stations are the ABC and NBC affiliates. All the others are LPTV's. I have not measured KCWQ our CW station but I would not want to fall asleep watching it but the increase in volume on the local spot inserts is giagantic.

 

[Brian Bowers]

Didn't radio have this whole loudness thing solved a long time ago? In other words, most radio station's average volume level is very consistent. Some stations are very compressed, some overly compressed, and the classical's and jazz stations more open...usually. I can't think of one radio station I listen to, where I am bombarded with loud commericals or music, so much so, that I need to go for the volume control. For the most part, radio's loudness is very consistent. Why did TV have such a problem following radio's trend? Most radio processors do a fantastic job of riding gain, along with a million other available adjustments. Couldn't those same processors have stamped with a label for TV, and marketed for TV? I know Orban used to make a processor for TV. As you can see, I've never been in TV, only radio.

 

[ncradioeng]

I think the problem is that the audio processing gear went to the dumpster when the DTV switch happened. Most stations pass through the network programs straight to the transmitter and have no control over anything. There's no level knob anywhere. Now you have the calm act gear and it's back to what is was before. And as we all know - digital is better.

 

[gtomas]

I think the problem is that the audio processing gear went to the dumpster when the DTV switch happened. Most stations pass through the network programs straight to the transmitter and have no control over anything. There's no level knob anywhere. Now you have the calm act gear and it's back to what is was before. And as we all know - digital is better.

That's one reason...

The other is TV content is different (lots of talk, pauses, quiet parts, nothing to fill in... ) and you can't compress it as much without noticeable artifacts.


Regards,
Goran Tomas

 

[gtomas]

Didn't radio have this whole loudness thing solved a long time ago? In other words, most radio station's average volume level is very consistent. Some stations are very compressed, some overly compressed, and the classical's and jazz stations more open...usually. I can't think of one radio station I listen to, where I am bombarded with loud commericals or music, so much so, that I need to go for the volume control. For the most part, radio's loudness is very consistent. Why did TV have such a problem following radio's trend? Most radio processors do a fantastic job of riding gain, along with a million other available adjustments. Couldn't those same processors have stamped with a label for TV, and marketed for TV? I know Orban used to make a processor for TV. As you can see, I've never been in TV, only radio.

Brian, did you take time to watch just a little bit of those videos? It would all make much more sense...

It's not an issue that no processing is used (well, somewhere that is the case, but not as a rule). Most TV stations do have processors. That's not a problem.

This is a change, a paradigm shift if you want - from peak normalization to loudness normalization. (Btw, some people are advocating that the same be made to the digital radio.)

There are two goals - loudness consistency. And a broadcast regulation where overprocessing and overly compressing the sound will not gain you benefit.

So far, the broadcast has been peak normalized. There were loudness wars, people pushing their processing in order to raise that average level more closer to the peak ceiling. Why? Because peak ceiling was the standard. That's what the regulator was measuring.

The change now in TV is that the peak ceiling is not a primary one. The average one is - loudness. And it's been set fairly low, making the peak level almost irrelevant.

Let's say you've pushed your processor so that your average level is at -10 dB below the peak level which sits at 0dB. The system has been peak based and you wanted to be as loud, or louder, than the competition. So you've adjusted the processor to have a peak-to-average level of 10dB. Now the regulator says: your average level - loudness, measures -10 dB, but the new standard requires your loudness to be -24 dB. You are required to reduce the output of your processor by 14 dB. And you do (otherwise you get fined).

So now your average level is at -24 and your peak level is at -14 dB. So you squeeze your processor further and reduce your peak-to-average level to 8dB. This raises your average level by 2dB while peak stays the same. Your average level is now at -22 and you peak level remains at -14 dB. But you are required to keep you average (loudness) at -24. It's now at -22. You need to reduce the output by 2dB and comply. So you do. You now have a very compressed sound with and average level of -24 and a peak level of -16 dB.

Your competitor is smarter... He has had a 10dB of peak-to-average ratio just like you, but when they said he needs to make his average level -24, he relaxed his processor and adjusted it so it has 15 dB of peak-to-average ratio, and adjusted the output so that his average level sits at -24, as required by the regulator. Your average level also sits at -24 (as required) but your sound is all squashed and compressed because it has a low small peak-to-average ratio killing all the micro-dynamics. His sounds much more alive and relaxed and has the transient impact and the micro dynamics. You are not louder, because your are both loudness matched! Squeezing your processor didn't help you at all.

Overprocessing your advertisements will no longer make them louder, because we (almost) don't care about the peak level anymore, we care about the average level. You can still squash your audio, if you want. But it no longer makes it louder as we measure how loud it is and keep it at the same loudness as everything else.

I've oversimplified things and I'm not technically correct here, but that's the point...


Regards,
Goran Tomas

 

[frankberry]

Well said, Goran!

 

[Brian Bowers]

I really wonder how much effort the FCC is going to put into enforcing these rules, on paper, and in the field. I would be very surprised if a ton of energy was put into this. If they do, what a waste of taxpayer dollars. Really, what lobbyist were they trying to please when they passed this act? Do I sound a bit cynical?

 

[Robert Bass]

Let me guess, this act only covers over-the-air stations, and totally excludes things like Cable and Satellite services. If that's the case, then channel 247 (TBS) on DirecTV could be unmatched in volume against say my local Fox affiliate (on DirecTV channel 4).

I would agree this act sounds like a complete waste of taxpayer money. In fact, I'd never even heard of it until this thread was started! If I've never heard of it, how many others out there have? What's next... TV promos running on every channel that say, “If you think our programming is louder at some times then at others, call 1-800-TV2-LOUD”?

R

 

[gtomas]

I really wonder how much effort the FCC is going to put into enforcing these rules, on paper, and in the field. I would be very surprised if a ton of energy was put into this. If they do, what a waste of taxpayer dollars.

There's really no change required... As for example in radio you are required not to modulate past 100% (without sub-carriers) and someone monitors that, in TV it's the same. Only now they will no longer monitor your modulation or peak level, but your loudness level.

Really, what lobbyist were they trying to please when they passed this act?

The viewers... TV viewers all around the country, irritated and annoyed by loudness jumps in TV broadcast (most often, loud commercials).


Regards,
Goran Tomas

 

[gtomas]

Let me guess, this act only covers over-the-air stations, and totally excludes things like Cable and Satellite services. If that's the case, then channel 247 (TBS) on DirecTV could be unmatched in volume against say my local Fox affiliate (on DirecTV channel 4).

I don't know the details of the scope of the regulation in USA.

In Europe, it does apply to all TV broadcast - OTA, cable, satellite, OTT, streaming. Everything. There's actually a hefty document (available here if you're interested) explaining how to comply on every single platform, codec used, etc. in TV distribution.

The goal is that when a viewer switches between TV channels, they are all at the same loudness and they are not blown away by how some channels are loud or need to turn up the volume on others, because the audio is so low.


Regards,
Goran Tomas

 

[gtomas]

I've tried to look for something short, so maybe this 2 minute clip will illustrate the benefits of loudness (as compared to peak) normalization in TV broadcast:

http://youtu.be/NR9nTYhZeVQ


Regards,
Goran Tomas

 

[w9wi]

I don't know the details of the scope of the regulation in USA.

From http://www.fcc.gov/encyclopedia/loud-commercials:

Q: What does the CALM Act require the FCC to do?
A: Specifically, the CALM Act directs the Commission to establish rules that require TV stations, cable operators, satellite TV providers or other multichannel video program distributors (MVPDs) to apply the Advanced Television Systems Committee's (ATSC) A/85 Recommended Practice ("ATSC A/85 RP") to commercial advertisements they transmit to viewers.

In other words, it DOES apply to cable/satellite/IPTV. However...

If that's the case, then channel 247 (TBS) on DirecTV could be unmatched in volume against say my local Fox affiliate (on DirecTV channel 4).

Unfortunately true, not because CALM doesn't apply to DirecTV, but because while the loudness on channel 247 must be consistent, it need not be the *same* as the consistent loudness on channel 4:

Q: Why do the rules only pertain to commercials?
A: The CALM Act does not address loudness differences between programs or channels on a given station or MVPD.

It is an act of a legislature, after all; it *must* have loopholes

_________________________________________________

Brian: really, it's almost unheardof for the FCC to seek out violations of *any* of its technical regulations. As with pretty much everything else in Part 73, it will only be enforced if someone complains.

I will say that our station has spent actual money (five figures) on loudness control, and the difficulty we've had getting delivery on some equipment suggests MANY other stations are doing the same.

_________________________________________________

You can read the referenced A/85 standard on www.atsc.org.

Personally, I think Goran's posts on this subject do a very good job of explaining what's going on here.

 

[PTBoardOp94]

Let me guess, this act only covers over-the-air stations, and totally excludes things like Cable and Satellite services. If that's the case, then channel 247 (TBS) on DirecTV could be unmatched in volume against say my local Fox affiliate (on DirecTV channel 4).

No, the law includes cable and DBS.

I would agree this act sounds like a complete waste of taxpayer money. In fact, I'd never even heard of it until this thread was started!

CALM was an unfunded mandate on everyone: the FCC, broadcasters, cable and DBS operators.

 

[rfry]

Beside the difference in perceptual audio "loudness" when switching from one TV channel to another, the greater annoyance to me is that even after I compensated for that using the audio gain control on my TV set (a nuisance in itself), still there are many cases when commercials are objectionably louder at that setting, on that channel than the program audio there.

This tends to follow certain commercials, almost regardless of the apparent loudness of the sound track(s) of the TV program just beforehand, and even the TV channels in which they are embedded.

In such cases I mute the audio of those commercials -- which probably is not the response that their sponsors are paying for.