CALM Act: Looking At Loudness At The Halfway Mark
On Dec. 13, 2012, two years after President Barack Obama signed it into law, the provisions of the CALM (Commercial Advertisement Loudness Mitigation) Act, which regulate the relative loudness of television broadcasts, will go into effect, with the FCC now officially mandated to oversee and enforce the regulations, issuing rules for comprehensive content loudness control across broadcast, network and pay television outlets as per on a 4-0 vote at the agency’s monthly meeting in Washington earlier this month.
According to the FCC, the one-year advance period creates sufficient time for programmers and networks to provide their distributors with certifications stating the commercials that accompany their programming are fully compliant with the new rules. The one-year mark is a good vantage point to look back on how the industry has responded with what has been a remarkable series of tests and testimonies that has led to not only landmark legislation for the broadcast industry but the rapid expansion of what had previously been a relatively obscure and narrow pro audio category of products that measure, monitor and manage loudness.
“Many manufacturers have developed gear to offer for this, some of it stand-alone hardware,” explains Dale Pro Audio Broadcast Sales Rep Joe Prout, including dedicated meters from manufacturers such as Dolby and TC Electronic. “But more of the frame/card-based audio and video processing manufacturers, such as Miranda, Evertz, Ward-Beck and Wohler, have begun to offer cards that include loudness-management functions on them, and some of the manufacturers of standalone loudness hardware, including Linear Acoustic and DaySequerra/DTS-Neural, have begun licensing their loudness-management algorithms to these frame-based manufacturers to include on their frame cards.”
Prout adds that since many of the stations and networks already have some of these frames in place, it’s an easier fix to just insert one or more of these cards in place. However, he adds, “I expect that as of mid-year 2012, as we get closer to the FCC rules having some teeth in them starting next December, there will be another round of folks making sure they’ve got what they need.”
Implementing compliant loudness control technology and practices for broadcast networks was mainly a combination of integrating existing systems with new products. At Comcast’s main operations center in Philadelphia, where broadcasts of the Phillies, Flyers and Sixers originate, Senior Audio Mixer Michael Giacalone says a Linear Acoustics LQ1000 was installed in the master control room that supplements the Dolby LM-100 meters already used in all control rooms. The Linear Acoustic Aeromax 5.1 was also implemented to establish the dialnorm at a facility-wide -24 dB LKFS, as per the Advanced Television Systems Committee’s (ATSC) A/85 Recommended Practices finding. (Dave Moulton has a great explanation of the LKFS Full Scale reference here.)
“It’s a matter of always having a meter in front of you, and of teaching people that whether you’re ingesting content from outside or creating [new] content, you’re always keeping the audio at -24,” he says. “It’s a matter of always having a meter in front of you, and of teaching people that whether you’re ingesting content from outside or creating [new content], you’re always keeping the audio at -24,” he says.
A source at NBC says the network added software upgrades to its existing Telestream transcoding systems to address loudness management that measure loudness of short-form content against the -24 dB LKFS standard. Long-form content is managed using Dolby LM-100 hardware meters and metering integrated with the network’s Miranda Kaleido multi-viewer systems.
Sports presents a unique challenge, the NBC source states; remote trucks are less-than-ideal monitoring environments, but they can be largely tamed in terms of relative level by a combination of experienced mixers using both their ears and accurate metering.
“The problem was when there was uncertainty about what they were supposed to deliver,” he explains. “The goal was to get rid of the ambiguity, and we’ve accomplished that.”
CBS VP Engineering & Advanced Technology Bob Seidel points out that the CALM Act regulates the loudness of commercials, not programming.
“All the commercials used in CBS Sports programs, CBS News programs, and all other CBS Television Network content, as well as the CW TV Network and CBS Worldwide Distribution, all come through a central ingest QC [quality control] point for loudness measurement, monitoring and control,” Seidel explains. “If the commercial exceeds the ATSC Recommended Practice A/85 limits, then we give the advertiser a choice of re-mixing the commercial or we will use our software- or hardware-based loudness controller to correct the commercial and maintain the upper and lower tolerances.”
CBS uses a TC Electronic hardware controller and the Telestream Flip-Factory audio loudness control software. CBS measures the “all channel loudness” parameter, as per ITU-R BS.1770. The process is fully automated and requires no operator intervention. “These practices and procedures have been in place even before the CALM Act was passed,” says Seidel.
The reality is that broadcasters have been implementing loudness monitoring and control for several years, ever since the advent of digital broadcasting, and much of that experience went into the writing of the specifications now being applied. Greg Coppa, director of advanced technology and engineering at CBS Labs, who helped write the A/85 specification, says that the legislation may add some layer of documentation to a process that’s been ongoing for the last three years. However, he adds that the law of unintended consequences may also apply: commercials with passages of silence could actually skew the measurement of loudness and cause the automated scaling algorithms to actually increase its overall loudness compared to a station’s set dialnorm value.
“We recently had an inquiry from an advertiser who wanted to run a silent commercial,” he recalls, acknowledging the irony of that in a year when a silent movie has been nominated for a Golden Globe Award. “Hypothetically, they could be breaking the law.” Coppa says that ITU-BS.1770-2, a 2011 revision of the BS.1770 recommendation for measurement of dialog loudness that adds a “gated loudness” algorithm to the process, could address that issue. He also adds that while broadcasters have paid attention to managing loudness as an industry in the last several years, the formalization of it as a regulatory issue means some documentation and other record-keeping technicalities still need to be clarified.
Bruce Goldfeder, director of engineering at CBS, says that training has gone on for several years preceding the CALM Act, with regular meetings on the topic with A1s in sports. “All our levels match now consistently,” he says.
Some had voiced concern that too much emphasis on smoothing audio loudness levels would result in a loss of dynamic range. However, Bob Seidel stresses, loudness control has not come at the cost of dynamics. “In dramas and comedies, the loudness of whispers should be different than shouts,” he explains. “We try to give the creative programming more latitude, since the loudness at the 18th hole of The Masters, when Tiger is putting, is not the same as the final buzzer at the Final Four.”