Feeling Worried? Or Feeling CALM?
At the time of this writing, it has been nearly a year since the CALM Act was signed into law and the date on which the rules of the CALM Act officially go into effect is getting closer.
The CALM Act itself and the broader topics of controlling and monitoring loudness have been the subjects of much conversation, some debate, and a good bit of confusion.
What the CALM Act Means to Broadcasters
On December 13th, 2011, the FCC moved to implement the 2010 Commercial Advertisement Loudness Mitigation (CALM) Act. On December 13th, 2012, the rules of CALM go into effect and the FCC will carry out its responsibility to enforce them.
In its simplest terms, this means over-the-air (OTA) broadcasters, cable operators, satellite television providers, and multichannel video program distributors must ensure that commercials have the same average loudness as the programs they accompany.
More specifically, it means applying the ATSC A/85 Recommended Practice - a set of methods to measure and control the loudness of digital audio - to commercial advertisements delivered to viewers.
While the FCC has placed a responsibility upon broadcasters to ensure compliance, it has also stated that enforcement will be primarily complaint-driven. If viewers establish a pattern of complaints, the FCC will address them; but if viewers are satisfied that stations and MVPDs have effectively controlled the loudness levels of commercials (as evidenced by a lack of complaints) there is unlikely to be a problem.
It's an accepted fact in digital television that audio levels can vary wildly between sources. Savvy broadcasters have already established systematic methods for both monitoring AND controlling those levels in their facilities. They've done so not only to comply with the "letter" of the law but also the "spirit" of the law, which endeavors to keep viewers happy, and happy viewers don't complain.
It simply comes down to not upsetting your viewers. Linear Acoustic continues to provide transmission encoding and processing equipment via our AERO line of products which ensure stations and MVPDs are in compliance by having a real-time processor installed and operating. We provide file-based loudness control and metering equipment for compliance with the "Safe Harbor" portion of the CALM act. Finally, we provide metering solutions that let operators keep a real-time eye on average levels and generate data that can be exported and archived should the station ever be called upon to prove compliance. Operators combining measurement and manual or automatic loudness control can then rest easy knowing they will have high quality audio, satisfied viewers and thus compliance.
Why Monitoring Alone Will Not Protect You
Among the many misunderstandings and misinterpretations of the CALM Act is the claim that simply by monitoring loudness, your facility will be compliant.
That's like saying that just because you have a speedometer in your car you won't exceed the speed limit, and therefore can't get a ticket. Or because you own a clock, you'll never be late. It simply isn't true.
It IS true that an ITU-R BS.1770 meter such as the Linear Acoustic® LQ-1000™ must be used to accurately measure LKFS loudness, but monitoring alone is not enough to ensure compliance.
Happy Meter? Or Happy Viewer?
Interestingly - and somewhat ironically - another common misconception is that as long as the meter hangs tight at -24dB LKFS, all is well. This situation is easily achieved by crushing the audio with a rudimentary processor at the very end of the audio chain, but that logic is faulty too. The CALM Act was created because viewers were annoyed by television audio - specifically loud commercials. Aggressively processing the audio is annoying, too, and isn't going to make for happy viewers. And at its core, that's what CALM is all about: Keeping your viewers happy so they have no reason to complain about your audio.
One of our favorite sayings at Linear Acoustic is "a happy meter does not necessarily make for a happy viewer." By this we mean that it's relatively easy to make a loudness meter read out a constant LKFS value; simply stick an unsophisticated compressor/limiter at the end of the transmission audio chain and you'll have a "compliant" meter reading all day long.
If you're wondering what that does to your audio, you probably already know the answer: It sacrifices quality, erodes the exciting and immersive experience that makes multi-channel television audio so compelling, and irritates viewers. The CALM Act is supposed to eliminate annoyances, not trade one for another.
All Linear Acoustic AERO-series products use available metadata values and sophisticated algorithms to deliver consistent loudness levels without sacrificing sound quality, and when properly adjusted per the user manual, result in audio that is pleasing to viewers and thus compliant.
Beginning-to-End Quality and Compliance
Achieving compliance and delivering viewer-pleasing audio isn't about finding a single solution. Rather, it's a comprehensive process that involves measuring and controlling audio throughout the entire facility from origination and ingest right through to final transmission.
Today's television programming comes from a wide variety of sources, including network feeds, locally produced commercials, syndicated programming (with its own commercial content), live news cut-ins from OB trucks, and local news programs.
Content from these sources should always be measured for proper levels and corrected as necessary by a file-based solution or by a dedicated hardware loudness controller.
Doing so eliminates the need to take a heavy-handed approach at the other end of the path, just prior to transmission, ensuring quality is preserved by the judicious use of a sophisticated transmission audio loudness manager whose output should be measured with a proper ITU-R BS.1770 meter to ensure compliance.
If you are concerned about whether your station is ready for CALM or would like to learn more about our beginning-to-end quality and compliance solutions, please visit our website at http://www.telosalliance.com/Linear.