NEW YORK—Stations around the
country have been busy the last
few months making preparations to
meet a new requirement that alters
how broadcasters measure and deliver
audio to TV viewers. The Commercial
Advertisement Loudness
Mitigation ACT, aka the “CALM Act,”
had some broadcasters scrambling
to satisfy new rules that took effect
Dec. 13. The act affects how stations
monitor the loudness of commercials,
a technical issue measured by
perception.
For decades, most stations measured
volume using a standard peak
meter, such as a simple VU or PPM.
Now, broadcasters are required to
measure loudness over time. This
new way of monitoring audio will
take some getting used to by stations
that now have to take into account
a temporal component. Aside from
making the necessary adjustments,
there is concern over how the FCC
will test and enforce the new rules
as stations adjust to the new method
of audio management and monitoring.
The commission will not audit
stations but enforcement will be
based on consumer complaints.
Along with the technical and financial
challenge of conforming
audio levels for CALM compliancy,
there are new needs in the areas of
monitoring and logging. A simple VU
or PPM meter no longer will suffice
as a station’s final quality check of
outgoing audio. There also is the issue
of providing proof that the audio
leaving a facility met compliance
standards.
To best manage audio to meet
CALM compliance, broadcasters
are implementing several solutions.
These plans range from simple
changes where a single box is
placed on the station’s outgoing
transmission path, to a more
holistic approach where some
broadcasters are trying to better
manage the audio within
their plants starting with media
ingest. The single box solution
is obviously the lower cost
option, but several industry experts warn that this might not be enough
to meet compliance and may actually degrade
the quality of a station’s final output.
TACKLING THE CHALLENGE
The transition from SD to HD drew
much attention to the quality of the
broadcast picture. Audio, however, has
often been a secondary priority. When
consumers conveyed their interest in 5.1
surround, most stations merely placed an
upconversion box on their stereo outputs
to synthesize a 5.1 surround experience
for the viewer. This was a low-cost solution
that placated most viewers, while buying
broadcasters the necessary time to assess
how they would address the challenge of
managing six channels of audio within
their plants.
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Tim Carroll |
The CALM Act—passed by Congress in
2010 in response to viewer complaints—
has put forth an audio implementation
challenge with legal ramifications, but in
the end it may actually leave more viewers
satisfied and provide broadcasters with
the opportunity to revisit how audio is
managed in their plants.
“It’s a good thing for the viewers,” says
Lee McPherson, San Francisco-based director
of engineering for the Cox group’s
KTVU. “In the daytime there is a wide range
of loudness levels… the act will help even
those out for the viewer.” McPherson adds
that the Cox Media Group, which owns 15
TV stations, has taken the challenge very
seriously and is attacking the issue both in
the baseband and media file domains.
His station group, as well as others has
found that the compliance mandate has
enabled them to pursue technologies that
are opening up whole new ways to manage
and monitor their
facility’s transmission
signals.
“Not only did we want
CALM compliance monitoring,
we were looking
for a vendor who would
help us with AFD, silence
detection and of course
closed captioning monitoring,”
says Jim Church,
senior vice president
and director of operations
and technology at
Allbritton station KATV in Little Rock, Ark.
“We had to spend the money for CALM
compliancy, why not get more bang for the
buck,” he said, referring to their effort to
pursue additional monitor options during
their upgrade.
“We run so many sub channels at all the
Allbritton stations, we wanted better overall
monitoring of our outgoing signals,” he
says. Like most stations they have one to
two people in their master controls, who
are often in charge of monitoring two to
three program streams. He acknowledges
the reality that operators can’t physically
monitor every frame of video and listen to
all the audio that goes through their MCR.
Church was the lead for the station group’s
compliance efforts and chose the VELA Research
ArgoNavis multiviewer to accomplish
all of the final transmission chain
monitoring, and deployed the same system
to all the stations in his group. This fourchannel
system gives their MCR operators
an extra set of eyes to monitor all outgoing
channels for audio levels, AFD, silence and
CC, and will alarm if any of the preset parameters
are not met.
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Lee McPherson, director of engineering for KTVU |
At KTVU, McPherson says they are taking
advantage of several new products that
do data logging of the audio signal levels
throughout their plant. Their engineering
department is using these logs both as
proof of compliancy as well as for auditing
the quality of the signals at various locations
throughout the plant.
Data logging will be an important tool
under the CALM Act, because it provides
proof that the the station’s outgoing levels
meet the required standards. Church says
that their systems not only provide logs of
CALM and CC compliancy; they also enable
the capture of screen grabs to see the
source of the non-compliant material.
“It goes beyond just providing an alert,
it logs all the information including a frame
capture at the time of the incident, and
even has an option for an
H.264 video capture,” he
said. Church’s station group
plans on keeping CALM
and CC log files for all station
output for two years,
in addition to their current
procedure of archiving 18
months of news and 45
days of programming confidence
video.
HOLISTIC APPROACH
“The goal of CALM
isn’t to get a meter to stand still at –24dB
around the clock, but rather to simply
make sure viewers are not annoyed,” said
Tim Carroll, founder and president of Linear
Acoustic in Lancaster, Pa. “If the audio
is smooth and consistent it is likely not to
generate any complaints and thus be compliant.”
He explains that loudness is subjective
and requires a different kind of meter,
and procedures for making measurements
to be made differently. The goal is not some
fixed loudness number, but one that is consistent
over time.
Many of the experts in the field of
broadcast audio recommend a holistic approach
to managing audio levels within
a broadcaster’s plant. “If you monitor and
log audio as it travels through the system,
you can analyze the logs to determine repeat
offenders or weaknesses in the chain,”
explains Thomas Lund, HD development
manager for Denmark-based TC Electronics.
Lund has spent years writing about
techniques and best practices for managing
audio for broadcast. He feels that it is
difficult to correct an audio problem if
one doesn’t know where it originates. To
properly monitor and track audio levels,
TC Electronics has numerous products to
meter the audio, chart its levels and then
to manage or conform the audio when
level correction is needed. Lund believes
strongly that audio should be corrected at
the end of the signal chain only to catch
issues that get through. The proper approach
should be to make sure all media
from ingest through edit be properly monitored
so that minimal corrections need to
be made at the end.
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Additional CALM Concerns
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Here is some additional information on program
rules and the complaint process under the CALM
Act, provided by the online resource Broadcast
Law Blog (www.broadcastlawblog.com):
• Noncommercial stations are exempt from the
CALM Act rules (unless they have commercial
programming in their ancillary and supplementary
digital services).
• Political ads are considered commercials for
purposes of these rules. The FCC determined
that any limits on the volume of these spots
are not editorial changes that would violate
the no censorship provision of Section 315 of
the Communications Act.
• Station promotional announcements and program
length commercial programming are
subject to the new rules.
• Successor standards to those currently set out
in A/85 (the ATSC standard under which the
standards for CALM Act is based) will be reviewed
by the Commission. If minor, they will
be adopted by Public Notice and become
part of the compliance obligations of stations
and systems. If they are more substantial
changes to the current standards, they will be
subject to public comment before they can be
adopted.
• The FCC will not audit stations for compliance.
Instead, enforcement will be on a
complaint-driven basis. If there are a pattern
of complaints about the compliance of
a station or system, the FCC will notify the
station or system, which will then need to
certify that their equipment is in place and
has been properly maintained. The station
or system will also need to demonstrate compliance
with the safe harbor, and potentially
it may need to do some spot checks on compliance.
• The complaints, to be considered by the
FCC, must be very specific as to the station or
system, channel, program, network and nature
of the problem for the FCC to investigate.
• Stations and systems do not need to buy monitoring
equipment, but may instead rent it for
spot checks or when there are complaints that
the FCC brings to their attention.
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Carroll agrees. “For recorded content
this means metering and correction at the
point of ingest, for live programs it may be
done on the OB truck or in the master control
environment.”
Getting all the various elements to the
targeted loudness level early means you
don’t have to process the signal as aggressively
at the final point in the transmission
chain. The goal is to leave the audio more
open, dynamic and pleasing to the viewer.
Even with vigilant
monitoring
there are ways
that material can
get around checkpoints.
“Sometimes
the station’s promos
are the worst
offenders, because
they have a way of
getting around the
QC system,” Lund
said. He states that
loudness is a “perceptual
standard”
so content level can only be judged when
it is next to differing material. A promo may
sound fine to an editor, but after a news
segment or a commercial, it may not match
up at all.
HOW WILL THE FCC ENFORCE IT?
The CALM Act introduces a new set of
rules and stations can’t know exactly how
the FCC may choose to enforce the regulations.
KTVU’s McPherson says “If the
law changes, we will change our solution
to maintain compliance.”
Since becoming compliant, the Allbritton
group says that it rarely gets calls anymore
about commercials being too loud.
Church’s feelings are that if syndicators
and networks are all compliant at –24dB,
“I’m not sure the commission will have a
lot of work to do.” He says that his group
has embraced CALM as a good thing to do.
He admits it can be expensive to implement
a full solution across multiple stations,
but says “frankly our stations sound
better.”
With the correct tools and proper
implementation of signal management
through a plant, experts agree that the end
product will sound be better.