Is Television Loudness Still an Issue?

It’s been nearly six years since the CALM Act – the bill passed to address the issue of loud television commercials – was put into effect in the U.S. We thought it a good time to re-examine the loudness issue in a series of blog posts. Here in Part 1 we’ll explore whether or not these legislative mandates have been effective and find out if content producers and broadcasters are still struggling with managing loudness in traditional OTA  and OTT distribution.

Are commercials still loud? 

In January 2013, the first full month after the CALM Act was in effect, the FCC fielded over 4,400 complaints about loud commercials. By December 2013 - nearly one year later - the number of complaints had dropped to under 700 and have been on the decline ever since. There are still some legitimately loud commercials getting through, particularly local cable insertion spots which are sometimes difficult to manage because of where they originate in the chain - but most complaints can be traced back to instances of perceived loudness rather than true non-compliant content.

One example of this is lower program audio that immediately precedes a commercial. If a perfectly compliant spot has the misfortune of airing after 10 seconds of quiet audio in the surrounding program, it will sound comparatively loud to the viewer who will incorrectly – though understandably – blame the commercial for being too loud.

This scenario points out what may be the most difficult real-world challenge with the CALM Act and the recommended practices upon which it is based, which focus on the average loudness in a given program segment. An intentionally quiet 30-second scene within a two-hour program poses no threat to maintaining the desired average loudness value, as there’s plenty of time to offset it with slightly louder passages.

A 30-second commercial has no such wiggle room and will need to stay much closer to the loudness target at all times, which will result in more consistent loudness. Commercials that are heavily processed during production – a technique that lowers the peak-to-average ratio – sound even louder but will still read as compliant when analyzed by an LKFS/LUFS meter. The same is true for commercials that make use of excessive peaks, a practice that is addressed in some but not all loudness regulations.

The need for real-time processing.

Until a few years ago, the bulk of the responsibility for loudness control fell squarely on the local station. Content from the major networks was delivered at compliant levels, but everything else – including commercials, live reports, sports, and syndicated programming – was unpredictable, and file-based analysis and correction wasn’t yet commonplace. That meant real-time transmission path processing had to be set up to handle a massively wide range of audio levels, which at times resulted in a flat, over-processed sound.

Some content still remains unpredictable. The news reporter that speaks at a normal level during a mic check might amp things up in the excitement of delivering a breaking story, and a bases-loaded-homerun in the bottom of 9th inning of a scoreless baseball game is a guaranteed overload from the play-by-play guy. Plus, there will always be the odd outlier of a commercial no matter how careful content producers and broadcasters are. For these reasons, real-time processing is still as important and necessary as it ever was.

Where are we now?

The good news is that content is much more under control than it’s ever been thanks to the combined efforts of content producers, networks, content distributors, and local affiliate stations, and the overall experience for viewers is vastly improved.

Next time around, we’ll take a closer look at how the adoption of effective automated file-based analysis and loudness correction tools has allowed many broadcasters the luxury of backing down on their final processing.

Further Reading

• File-based processing automation increases productivity and decreases costs. Here's how!
• Revolutionizing Internal Communications with Highly Flexible and Scalable AoIP Intercom Solutions

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