The clock is ticking down to Dec. 13, when
the FCC will finally begin enforcing the Commercial
Advertisement Loudness Mitigation
(CALM) Act. While operators don’t need to panic
yet, they need to act now to get into compliance
and avoid potentially significant fines.
The CALM Act requires all video service
providers to tone down commercials so a
consistent audio level is maintained from
program to interstitial material. Failure to
do so may result in fines, which could add up
quickly for operators given the hundreds of channels and
thousands of ads they deliver daily. Complicating matters,
most operators cannot identify all of the national and local
commercials they run, let alone identify, measure, log
and isolate the loudest ones.
The FCC will use consumers as its primary means of monitoring
compliance, evaluating their complaints to determine
possible violations. The complaints will then be forwarded to
the operators so corrective action can be taken. The FCC can
investigate incidents more closely, requiring proof of compliance
and that operators in violation explain the violation and
provide a corrective action plan. Fines will serve as the act’s
primary enforcement tool.
Loudness Standards Established
The CALM Act mandates that the FCC adopt and enforce
the digital television audio loudness recommendations made
by the Advanced Television Systems Committee. These
standards, known as ATSC A/85 RP, along with the ITU-R
BS.1770 measurement algorithm, are at the heart of the act.
Essentially, ATSC A/85 RP provides guidance to MSOs
regarding acceptable audio levels when broadcasting
programs and ads.
The ITU-R BS.1770 algorithm provides
a numerical value indicating the perceived
loudness of content that is then encoded into
the audio by the content provider as metadata
called a “dialnorm.” Set-tops and other receivers
will automatically adjust the volume
based on the dialnorm value to eliminate volume
ATSC A/85 RP provides two primary means for MSOs to
control content loudness in compliance with the CALM Act.
The first is hardware-based equipment. The second depends
on the operator’s content providers — clearly a less reliable
means of ensuring compliance.
Any hardware solution must have certain characteristics
to meet an operator’s CALM compliance needs. First, it must
analyze and report audio levels using the db LKFS measurement
so it can track hundreds of programs and commercials
in real-time. In addition, it must establish and support alert
settings and thresholds, identify excessively loud segments,
determine trends from historical data and maintain a loudness
Fortunately, just such a class of high-density loudness
monitors with these characteristics is now available. What’s
more, these monitors can be deployed quickly, so operators
can remain calm as they still have time to comply before Dec
Steve Liu is vice president, video network monitoring,
at Beaverton, Ore.-based Tektronix, a maker of test,
measurement and monitoring devices.