Video-streaming services delivering content to the state of California will soon be required to change the way they handle advertising to alleviate one of viewers’ biggest annoyances: Loud commercials. Thanks to Senate Bill 576, signed into law in October 2025 and taking effect on July 1, 2026, commercials can no longer be noticeably louder than the surrounding program.

Broadcast and cable television providers have been adhering to the Commercial Advertisement Loudness Mitigation Act—better known as the CALM Act —since it was signed into law in 2010 to address this same issue, but it has not applied to streaming services.

The new legislation closes that gap, requiring streaming platforms to follow the same practices outlined in CALM, which itself is based on the recommended practices outlined in ATSC A/85, ensuring that ads are delivered at the same volume as the rest of the program content.

Are You Being Served?
To understand how this impacts streaming services, it helps to look at how ads are actually delivered on these platforms. The two main approaches are client-side ad insertion (CSID) and server-side ad insertion (SSID).

Client-side means the ads are added into the stream by the app or device itself. CSID is flexible and allows for targeted ads, but controlling levels is challenging, as every device handles playback differently.

Server-side, on the other hand, stitches ads into the stream before it ever reaches the viewer. SSID behaves more predictably and is often preferred as it helps counter ad blockers, but it introduces its own challenges since different vendors use different encoding pipelines, which can result in inconsistent loudness.

Streaming providers employ these models in different ways. National broadcasters like NBC, CBS, ABC, and Fox already comply with the CALM Act for their traditional broadcasts, so extending those practices to their streaming apps is a natural next step.

Major streaming services such as Netflix, Hulu, Disney+, and Amazon Prime Video are also affected. Netflix recently introduced an ad-supported tier, Hulu and Disney+ lean heavily on server-side insertion, and Amazon Prime’s hybrid model mixes subscription and ad-supported content.

Local broadcasters face a unique challenge, as they often depend on third-party server-side ad insertion vendors for their streams, meaning they will need to ensure those partners are meeting California’s new requirements.

The biggest impact may be felt by FAST (Free Ad-Supported Television Services) channels like Pluto TV, Tubi, and Freevee. These platforms rely almost entirely on server-side ad insertion, pulling ads from a variety of suppliers, making them especially vulnerable to loudness inconsistencies.

Video-on-demand providers face their own challenges, as many of them use client-side ad insertion that requires normalization at the device level. This approach makes consistent loudness more difficult and requires VOD platforms to ensure loudness metadata is included and preserved so that the playback device can adjust levels accordingly.

Overcoming Technical Challenges
The technical hurdles to comply with this new regulation are significant. Different server-side ad insertion providers use different encoding methods, which means ads can arrive with varying loudness levels. Ads themselves often come from multiple sources, each mastered to different standards.

On top of that, playback devices—from smart TVs to mobile phones—interpret audio differently, which makes it even harder to guarantee a consistent experience. Content created before the legislation was enacted adds another wrinkle, since it may not meet modern loudness standards and would need to be reprocessed.

So how do streaming platforms tackle this? The first step is becoming familiar with ATSC A/85 recommended practices, which guide CALM compliance and, in turn, adherence to the new streaming regulations. Streaming providers will need to integrate file-based and, in some cases, real-time processing and loudness control into their server-side commercial insertion workflow, just as they currently do for their primary programming.

For client-side insertion, ensuring that loudness metadata is included and maintained is a promising option. Measuring loudness at ingest (to determine the need for corrective measures) and downstream (as a final QC step before distribution) using the latest iteration of ITU-R BS.1770 is critically important.

California’s new law is a big step toward making streaming feel more polished and viewer-friendly. For national broadcasters, it’s an extension of practices they already follow. For FAST channels and VOD providers, it’s a wake-up call to tighten up their workflows.

The challenges are real, but the solutions are within reach. By adhering to established loudness measurement, enforcing metadata-driven normalization, and holding vendors accountable, streaming platforms can not only comply with the law but also deliver a smoother, more enjoyable experience for viewers.

The California State Legislature has passed a new law that extends federal TV-commercial volume rules to cover streaming.

On Tuesday, Gov. Gavin Newsom signed SB 576 by Sen. Thomas Umberg (D-Santa Ana) to turn down the volume of commercials that rise to a level louder than the primary video content being watched.

When Congress passed the Commercial Advertisement Loudness Mitigation (CALM) Act in 2010, the law only applied to broadcast television stations and cable operators. Gov. Newsom noted that the state’s new rules extend those limits now to streaming services, which have skyrocketed in popularity over the past decade.

“We heard Californians loud and clear, and what’s clear is that they don’t want commercials at a volume any louder than the level at which they were previously enjoying a program,” Newsom said. “By signing SB 576, California is dialing down this inconvenience across streaming platforms, which had previously not been subject to commercial volume regulations passed by Congress in 2010.”

“This bill was inspired by baby Samantha and every exhausted parent who’s finally gotten a baby to sleep, only to have a blaring streaming ad undo all that hard work,” said bill sponsor Umberg. “SB 576 brings some much-needed peace and quiet to California households by making sure streaming ads aren’t louder than the shows we actually want to watch.”

Even though many critics say the current laws on the books are not being adequately enforced, opponents argued that the new rules will be even harder to enforce.

“Unlike in the broadcasting [and] cable network environment, where advertisers sell their ads directly to the networks, streaming ads come from several different sources and cannot necessarily or practically be controlled by streaming platforms,” Melissa Patack, the MPA’s vice president of state government affairs, testified last summer.

Earlier this year, the FCC issued a Notice of Public Rulemaking (NPRM), seeking public input on the effectiveness of the current rules. That NPRM acknowledged streaming but did not suggest that the rules be extended. Closing date for public comments was in May, the FCC has not taken any more action since.

The law, which covers television broadcast stations, cable operators, and other multichannel video programming distributors in addition to streaming services, was so simply written that we feel comfortable publishing it verbatim:

“Existing law regulates various businesses to, among other things, preserve and regulate competition, prohibit unfair trade practices, and regulate advertising.

“Existing federal law requires the Federal Communications Commission to develop regulations that require commercials to have the same average volume as the programs they accompany. The federal regulations apply to television broadcast stations, cable operators, and other multichannel video programming distributors.

“This bill would prohibit, on and after July 1, 2026, a video streaming service, as defined, that serves consumers in the state from transmitting the audio of commercial advertisements louder than the video content the advertisements accompany, as specified. The bill would state that it does not create a private right of action.”

Costa Nikols, executive team strategy adviser, Media & Entertainment, for Telos Alliance, said that since the passage of the federal CALM Act, television has drastically changed to on-demand and OTT platforms where audio levels for commercials remain unregulated.

“California’s new streaming regulations mark an important first step toward improving the viewer experience,” Nikols said. “The industry now has an opportunity to apply the same discipline to streaming audio that transformed broadcast. Audio processing that can help broadcasters with streaming content loudness levels will be in increased focus as companies push to maintain dialogue intelligibility and quality. We saw it before with broadcast—the right technology is already in place, so the industry should feel ready to do it again.”

WASHINGTON—The FCC has launched a public inquiry into updating the rules that guide the Commercial Advertisement Loudness Mitigation (CALM) Act, noting that a recent increase in consumer complaints warrants the commission to take a “second look.”

FCC Chairman Carr announced his intentions to revisit the Act earlier this month and at its February meeting on Thursday, all four current members voted to approve the Notice of Proposed Rulemaking (FCC 25-16). (President Trump’s nomination for the sixth member, Olivia Trusty, is awaiting Congressional approval).

Although the vote was unanimous, Commissioner Geoffrey Starks raised issues about the NPRM, noting that the commission’s initial desire to extend the rules to streaming could conflict with the Act’s original focus, which was on broadcast TV.

“Many of the complaints that triggered this item were against streaming providers,” Starks said during the commission’s meeting on Thursday. “While the Commission has generally considered these providers to be outside the scope of our authority, at least under the Communications Act, this item seeks comment on our authority to extend commercial loudness requirements to these providers, under either the CALM Act or the CVAA. I believe this would be a new reading of these laws… so we must tread carefully.”

Starks thanked Carr for eliminating the streaming provision.

“Addressing commercial loudness regulations must not— like the proverbial wolf in sheep’s clothing—morph into this Commission expanding its authority to cover streamers in other, more substantive areas,” he said. “I expressed these concerns to my colleagues, and I want to thank the Chairman for agreeing to my edits that make two things clear. First, that this item proposes no specific regulations on streaming providers. And second, that the Commission will not proceed with any such regulation against any streaming provider without first seeking public comment in a subsequent Notice of Proposed Rulemaking – not today’s NPRM. We must provide ample notice and develop a substantial record in order to justify any future novel action."

Congress passed the CALM Act in 2010 and by 2012, the FCC implemented rules requiring television stations, cable operators, and satellite video providers to ensure that commercials are transmitted at appropriate volume levels. The FCC says it initially saw a decrease in the number of consumer complaints after these rules became effective. Over the past several years the Commission received thousands of complaints about loud commercials on broadcast, cable, and satellite television, but the high number of complaints took a troubling jump last year, which warrants a second look, the commission said.

“Today’s action seeks input from consumers and industry on the extent to which the CALM Act rules are effective in controlling and preventing loud commercials on programming provided by television broadcasters and pay TV providers like cable and satellite. The NPRM also considers what actions the Commission, industry, or standard developers could take to further minimize consumer harm,” the commission said.

Carr chimed in.

“If there’s one thing TV viewers hate more than annoying commercials, it would be loud, annoying commercials,” Chairman Carr said. “And judging from my own experiences talking recently with neighbors and relatives at family gatherings, this issue is top of mind for a lot of people—second only, perhaps, to concerns about robocalls. I want you to know that I hear you clear and loud. And I want to see what the FCC can do to help. After all, this is not the first time this issue has come up. Back in 2010, Congress provided the viewing public with some relief from these audio assaults when it passed a law called the CALM Act. Then in 2011, the Commission adopted rules to implement this law in an effort to eliminate the scourge of shouty ads at volumes far above normal listening levels.

“In the years immediately following the FCC’s adoption of those rules, consumer complaints about loud commercials dropped significantly. But unfortunately, in recent years, as my own experience confirms, we’ve seen an uptick in consumer complaints. So today, my FCC colleagues and I are taking action.”

WASHINGTON—In the run-up to its Feb. 27th Open Meeting, the Federal Communications Commission has issued further details on its plans to possibly update CALM Act rules that prohibit overly loud commercials.

As part of those plans, the FCC Media Bureau has opened MB Docket No. 25-72, which is captioned “Updates to the Commission’s Rules Implementing the Commercial Advertisement Loudness Mitigation (CALM) Act.”

It also released a document on Feb. 6 that has been circulated to the FCC commissioners for tentative consideration prior to its February 27, 2025 open meeting. The proposed Notice of Proposed Rulemaking, which will be voted on by the commissioners during the meeting, calls for public input on whether the FCC should updating CALM act rules.

The FCC stressed that the issues referenced in this document and the Commission’s ultimate resolutions of those issues remain under consideration and that the document does not constitute any official action by the Commission, the FCC reported.

In a blog post announcing the agenda for the February Open Meeting on Feb. 5 Carr said the agency will revisit the CALM Act, which was passed by Congress 15 years ago to require broadcasters to work with MVPDs to reduce the volume on TV commercials.

“Loud TV commercials are a frustrating headache,” Carr wrote. “You’re sitting there, chilling out, and then BOOM some commercial breaks in at a high volume. I don’t like them, and I’m pretty sure you don’t either. In fact, the FCC has recently seen an uptick in consumer complaints about excessively loud commercials.

“Back in 2010, Congress passed a law to address this issue, but given the rise in complaints I think now is the time for the FCC to revisit the issue,” he added. “Accordingly, we will consider a notice of proposed rulemaking to see if there are additional actions the Commission could take today to make sure TV viewers aren’t inundated by exceedingly loud commercials.”

In the proposed Notice of Proposed Rulemaking the FCC noted that “in the years immediately following [the adoption of rules implementing the CALM act], consumer complaints dropped significantly, indicating real efforts on the part of industry to bring their stations or systems into compliance. Nevertheless, in recent years, the Commission has received thousands of complaints from viewers who remain frustrated by the loudness of television commercials. This Notice of Proposed Rulemaking asks viewers and television industry participants whether there are additional actions the Commission could take today that would support the purposes of the CALM Act.”

The FCC said the proposed Notice of Proposed Rulemaking would: “seek feedback from stakeholders about whether the Commission’s CALM Act rules and practices are effectively serving their intended purpose and on specific areas in which commenters believe updates are needed given improvements in technology or new industry practices.”

In addition it would “seek comment on possible actions the Commission, industry, or standard developers could take to further minimize the problem...Invite consumers to tell us their experiences regarding the loudness of commercials as they watch programming provided by television broadcasters and MVPDs [and] consider if changes are needed to the consumer complaint process.”

WASHINGTON—FCC Chairman Brendan Carr has called for new spectrum auctions for wireless mobile as well as revisiting rules regulating TV loudness.

In a blog posted on Wednesday, the new chairman outlined his plans for the first FCC meeting scheduled for Feb. 27 and cited the aftereffects of Hurricane Helene to advocate for expanded wireless spectrum availability, particularly for first responders.

“Last Friday, I took my first official trip as FCC Chairman, visiting parts of North Carolina that were hit hard by Hurricane Helene,” Carr said. “I met with 911 operators who handled a sixfold surge in calls during the peak of the storm, first responders who led rescue and recovery efforts, telecom workers who quickly restored communications in difficult conditions, and local broadcasters who provided vital information to their communities. These visits only underscored the importance of robust, resilient, and affordable connectivity for Americans across the country. That is why we are taking action right out of the gate to get more spectrum into the hands of consumers—spectrum that can power new connections and innovations.”

To address these deficiencies, Carr said the commission will be “laser-focused on accelerating efforts that can get more spectrum into the marketplace. “

Carr characterizes the auction of AWS-3 spectrum licences—a band of RF used primarily for mobile broadband and public safety—as a “win-win.” He said he hopes to “kick-start” the process this month to complete it by June 23, 2026.

“It brings new spectrum into play for commercial use,” he said. “And the proceeds from this auction will also cover the costs of the national security initiative known as ‘rip and replace’—an effort that is removing untrustworthy technology, like Huawei and ZTE gear, from networks.”

In a move sure to get the attention of broadcasters, Carr also called for opening up additional portions of the C-band spectrum for 5G. Used mostly by TV and radio broadcasters for satellite downlinks, broadcasters have opposed efforts to expand usage of C-band over concerns of interference, particularly for ENG.

Carr hasn't been shy in advocating for more spectrum auctions. At last year’s Advanced Television Systems Committee (ATSC) annual meeting, Carr suggested that auctioning off additional broadcast spectrum would be on the block.

Carr also said the commission plans to vote on final rules to give emergency managers and consumers greater flexibility when it comes to Wireless Emergency Alerts, in particular, deciding when to issue alerts strategically in order to avoid so-called “alert fatigue” (aka “Boy Who Cried Wolf” syndrome).

Carr also said he will revisit the CALM Act, which was passed by Congress 15 years ago to require broadcasters to work with MVPDs to reduce the volume on TV commercials.

“Loud TV commercials are a frustrating headache,” Carr wrote. “You’re sitting there, chilling out, and then BOOM some commercial breaks in at a high volume. I don’t like them, and I’m pretty sure you don’t either. In fact, the FCC has recently seen an uptick in consumer complaints about excessively loud commercials.

“Back in 2010, Congress passed a law to address this issue, but given the rise in complaints I think now is the time for the FCC to revisit the issue,” he added. “Accordingly, we will consider a notice of proposed rulemaking to see if there are additional actions the Commission could take today to make sure TV viewers aren’t inundated by exceedingly loud commercials.”

WASHINGTON—The FCC Media Bureau is ready to take a look and its rules regarding the Commercial Advertisement Loudness Mitigation (CALM) Act, officially asking for comment from consumers and industry members.

The Media Bureau officially issued a Public Notice inviting comments, giving a deadline of June 3 for comments, with reply comments then due on July 9.

The CALM Act was enacted in 2010 by Rep. Anna Eshoo (D-Calif.) with the goal of regulating the volume of broadcast, cable and satellite commercials compared to other programming so that they are not significantly louder. The FCC adopted implementing rules in 2011 that require TV stations and MVPDs to ensure all commercials transmitted to consumers are at the appropriate loudness level. The FCC acknowledges that the rules have only been revisited once in the last 10 years, with minor changes adopted.

Eshoo has been calling on the FCC to revamp its efforts for the CALM Act, both under former FCC Chairman Ajit Pai and now under Acting Chairwoman Jessica Rosenworcel. She points out that there have been “thousands of complaints,” and yet there has never been any enforcement related to these complaints.

The FCC is now seeking comment on the effectiveness of its rules on preventing loud commercials. The commission says that it particularly wants comments from consumers and their viewing experiences. Input from all stakeholders on whether the FCC’s CALM Act rules are serving their intended purpose are also sought, with hope that commenters will share what they believe are necessary updates.

“Comments filed will help inform the commission’s determination of whether to take additional actions—and if so, what measures should be proposed or taken—in furtherance of the purpose of the CALM Act to prevent television stations and MVPDs from transmitting commercial advertisements at louder volumes than the program material they accompany,” the Public Notice reads.

Comments can be filed through the FCC’s Electronic Comment Filing System or mailed to the commission. Hand drop-off is still prohibited because of the COVID-19 pandemic.

For more information, visit www.fcc.gov.  

WASHINGTON—Rep. Anna Eshoo (D-Calif.) wants the FCC under Acting Chairwoman Jessica Rosenworcel to investigate the recent rise of complaints related to the CALM Act, and hopefully have the commission go a step further than it did under former FCC Chairman Ajit Pai when it comes to enforcement.

The CALM (Commercial Advertisement Loudness Mitigation) Act, which Eshoo wrote and was enacted in 2010, is designed to regulate the volume of broadcast, cable and satellite commercials compared to other programming, with the goal of preventing commercials from being significantly louder. The FCC was directed to issue regulations for the bill.

In a letter from Eshoo to Rosenworcel, she details how she originally contacted Pai on July 21, 2020, requesting information about new complaints related to the enforcement of the CALM Act. She said his response, sent on Aug. 11, 2020, indicated that while the FCC has received “thousands of complaints,” it has never brought an enforcement action as a result. Pai also said that CALM Act complaints were increasing in the first half of 2020.

Eshoo cited a recent press report from Insider using more recent data that shows complaints have increased from April 2020 through February 2021. The article says that “2021 is poised to be the worst year since the initial rollout” of the CALM Act.

“It is for these reasons that I ask the FCC investigate the rise in the loudness of TV advertising complaints and take enforcement actions as appropriate,” Eshoo wrote.

The FCC previously updated its enforcement of the CALM Act in 2014 (then under former FCC Chairman Tom Wheeler), implementing a new measurement algorithm that disregarded quiet or silent parts of commercials, which was proving to be a loophole with advertisers trying to use silence to offset loudness and lower the average volume of a commercial.

WASHINGTON—Back in July, Rep. Anna G. Eshoo (D-Calif.) challenged the FCC to provide a 10-year check-up on how the commission has been enforcing the CALM Act that Eshoo introduced in 2009 regarding the loudness of TV commercials.

In a letter to FCC Chairman Ajit Pai, Eshoo says that she is not aware of any instances of the FCC bringing enforcement actions under the law. She does not believe this is because the problem has been resolved, citing “thousands of consumer complaints about loud television commercials” that the FCC has received. Eshoo also raises the question of whether the CALM Act needs to expand because of the rise in consumer video services.

As a result, Eshoo asked the FCC to provide information regarding how many complaints have been made each year since 2008 and details on the action the FCC has taken since the CALM Act was passed.

PLUS: TV Loudness: The Wild, Wild West

Pai’s response to Eshoo’s request provided such details and how the FCC deems whether a station is in compliance with the CALM Act.

Between 2011 and 2012 the number of complaints regarding loudness of TV commercials shot up from a few hundred to multiple thousands, with a peak occurring in 2013 with 16,310 complaints filed by consumers. The number of yearly complaints has decreased in 2019 to 1,877—as of July 31, the number of complaints for 2020 was at 1,241, according to Pai’s statistics.

“[T]he number of overall complaints has trended downward dramatically since 2013, which may be due to the efficacy of the CALM Act and the technical standards promulgated by our rules,” Pai said.

He also notes that since 2013, during which the FCC sent to letter of inquiries to companies over potential violations, the commission “has not uncovered any pattern or trend of complaints supporting further inquiry.”

As for providing data on whether or not the CALM Act should be expanded, Pai said that the FCC does not have authorization to tabulate radio and streaming data related to loudness.

Pai’s full response to Rep. Eshoo is available online. 

CHAMPAIGN, Ill. – Oct. 28, 2019 – Cobalt Digital today announced Chicago-based Weigel Broadcasting Co., which owns and operates stations in nine markets in addition to MeTV and other digital multicast networks, is using Cobalt’s software defined 9922-FS-DSP platform for openGear® frames to provide microservices for Emergency Alert System local insertion and CALM compliance for its terrestrial stations. Most recently, the company purchased five cards in March for KTLN, a Heroes & Icons and MeTV affiliate serving San Francisco (DMA #8).

“It’s one of the few cards of its kind that is flexible,” explained Kyle Walker, vice president of technology for Weigel Broadcasting. “It’s the Swiss Army Knife of cards. This card can literally do it all at the right price point.”

Weigel has deployed dozens of 9922-FS-DSP cards, which offer a combination of rich broadcast connectivity and flexible microservices that make them cost effective options for many applications. The +EAS option allows Weigel to key EAS text crawls into active video and insert station logos. Some stations also add the +TTS option, which provides Text-To-Speech conversion of EAS text.

The 9922-FS-DSP also assists with compliance with the CALM Act, which requires commercials to be broadcast at the same volume as programming. Walker said a simple addition of a microservice for the 9922-FS-DSP makes it easy for Weigel to maintain CALM compliance for new digital subchannels and other broadcast properties.

For select remote locations, where an entire openGear frame is not necessary, Weigel uses Cobalt’s BBG-1022-FS-DSP, a standalone version of the 9922-FS-DSP. For installations that require cards from multiple vendors, Walker praised the openGear modular system. “It’s a great platform that allows several different vendors to play in the same sandbox,” he noted.

The 9922-FS-DSP offers a software defined platform that supports multiple microservices such as automatic audio leveling, upmixing, Dolby encoding and decoding, automatic SAP generation, EAS insertion, logo insertion, Text-To-Speech, and more. The base platform includes advanced frame sync features with per-channel audio delay and routing, as well as audio/video offset adjustment. Presets allow custom card setup, while layered presets allow changes related only to a specific function. Access to full control and monitoring is available through Cobalt’s DashBoard™ software or remote control panels.

About Cobalt Digital
Cobalt Digital Inc. designs and manufactures award-winning edge devices that help live video production and master control clients transition to IP, 4K, HDR, the cloud, and beyond. As a founding partner in the openGear® initiative and proud member of SMPTE, Cobalt also offers a best-of-breed interoperability platform that simplifies technological adoption. Distributed through a worldwide network of dealers, system integrators, and other partners, Cobalt Digital products are backed with a five-year warranty. Learn more at www.cobaltdigital.com. 

ASHLAND, ORE.—Back in the day of three television networks, analog NTSC, and epic westerns, radio stations engaged in endless loudness wars, but television stations strove to match their audio loudness with other stations in the market.

Those were the days! Commercial producers, of course, tried to make their commercials as loud as they could get away with. This was a constant battle, with the commercial producers maintaining that their product did not deflect the vu meter any higher than program audio.

We knew, of course, that although that was true, loudness could be increased through using audio compression to increase the average audio level, while keeping the peak level legal. So the vu meter did not go too high, but it dwelt near the peg. From the network side, there was constant effort to keep commercials from being offensively loud.

ONE MORE DB

As we moved into the digital age, this battle continued, but now the program producers also wanted to push audio levels to the limit. As the person who wrote and maintained the high-def program delivery spec for a major broadcast network, I engaged in many conversations with program producers about the audio levels on their programs. I remember one producer insisting passionately that they really, really needed that extra one dB that got their show rejected.

The digital television era also brought us 5.1 channel sound to accompany HD, and I recall one energy water commercial that pegged the peak meter of every audio channel, including the surrounds and the subwoofer, aka Low Frequency Effects. Meanwhile, another network went for maximum loudness as an objective, a practice that continues to this day.

The loud commercials situation produced the Commercial Announcement Loudness Mitigation (CALM) Act, a law with a clever title. Let me quote the opening paragraph of the FCC’s web page on the Act:

Federal Communications Commission (FCC or Commission) rules require commercials to have the same average volume as the programs they accompany. In the Commercial Advertisement Loudness Mitigation (CALM) Act, Congress directed the FCC to establish these rules, which went into effect on December 13, 2012.

As a loudness reference, the FCC mandated use of ATSC A/85, “ATSC Recommended Practice: Techniques for Establishing and Maintaining Audio Loudness for Digital Television.” From what may be determined from the ATSC website, A/85:2013 appears to be the current version of this Recommended Practice. It specifies the use of AC-3 tools such as Dialnorm and Dynrng , and also use of the loudness measurement algorithm contained in ITU BS.1770, updated in 2013 to BS-1770-3, which included a better loudness algorithm than BS.1770. In fact, BS.1770 is currently up to BS.1770-4, published in 2015, but it does not appear that the ATSC documentation has caught up. 

[Read: CALM Act Facts Revealed]

Parenthetically, your author worked on some of the early stages of the development of BS.1770, as did many audio experts. A number of algorithms were considered, going back as far as the algorithm used in the CBS Loudness Meter devised in the 1960s, and it is accurate to say that, while the CBS loudness algorithm was indeed better than some of the more recently devised ones, the algorithms used to measure perceived loudness have seen real improvement in recent years. The FCC regulations apply to broadcast, cable, and satellite TV, but not to internet. Sounds good, right? Or does it?

IN THE REAL WORLD

For a while now, I have been out of the loop, a pure viewer, and my observations have been that these regulations are frequently honored in the breach. Particularly in the cable world, audio loudness levels vary dramatically between channels, which is not, in itself, a violation; but it is distracting to the viewer, many of whom switch among channels.

In the AC-3 world, the honest, reasonable application of Dialnorm should render this a non-problem. On the broadcast side, there is, at least, consistency in the average loudness level of programming, element-to-element, as the broadcast networks take pains to assure it. The commercials, however, are a different story. Sometimes, the levels vary commercial-to-commercial, with some commercials being softer than the program material, and some louder.

There is one broadcast network whose commercials and network promos are consistently louder than their program material. I have confirmed this by noting it in a large market and a smaller market. And because I now live in market #138, the local commercials inserted into the pods are notably worse than the network commercials, on all network affiliates. This is partially because this market would seem to be where all the 1960’s screaming puker DJs ended up, now doing local commercial voice overs. A number of the locally produced commercials are not just loud, they are totally obnoxious. There are of course some very well-produced local commercials as well. Some.

Cable is frequently worse than broadcast for loud commercials and uneven commercial loudness. The worst, of course, is commercially-supported online TV. It appears that the commercials are typically inserted from different servers from the one that runs the programming, and possibly from multiple servers during a single commercial pod. The non-commercial streaming services with which I am familiar do a nice job of maintaining even program loudness. The commercially-supported services, i.e., the online streaming services of the broadcast and cable networks, are still on a steep learning curve with regard to relative loudness between program and commercial elements.”

To sum up, it appears that in 2018, the CALM Act is about as helpful to the consumer as the Do Not Call List.

Immersive audio took off in a huge way in 2014, especially in cinema with the release of films in Dolby Atmos and Auro 11.1 formats. The Traumpalast in Backnang, Germany was one of the first theaters to install a Dolby Atmos system, which includes a total of 57 speakers.

Here we are at the beginning of 2015, and as with all new years it is fashionable to analyze how the previous year went and take a look at how this new one might unfold. In this column dated Jan. 1, 2014, I made some predictions about what I thought the big stories of the year would be in the world of television audio. So let’s assess my prognostication skills and see whether they’ll hold up this year.

# 1: REFINEMENT OF THE CALM ACT—INCORRECT
My first prediction of last year was that the CALM Act would be further refined to make it easier to understand and implement, and this simply did not happen. There was almost no movement around the CALM Act this year other than the FCC finally adopting the 2013 revision, and the ATSC winning a well-deserved Primetime Emmy for A/85.

The rest of the year turned out rather quiet on the loudness front (pun definitely intended), with consumer complaints tapering off from an initial surge. Whether this is due to consumers actually being satisfied with the results of CALM implementation— or because they’ve given up reporting because they see no public vilifying of broadcasters over loud commercials—is something we don’t yet know; but most broadcasters seem to be doing a good job of keeping loudness under control.

It will be interesting to see what happens as initial two-year waivers expire; whether the FCC will allow extensions to those waivers due to the adoption of A/85:2013; and whether there will be any significant enforcement of the CALM Act. I think we’ll see some minor news regarding CALM this year, but it is unlikely to be anything significant.

# 2: AUDIO OBJECTS, NOT IMMERSIVE AUDIO—INCORRECT
It may not have been possible to be more wrong about this prediction than I was, and it’s partially the result of attending events where discussions take place regarding technology that remains years away.

Since audio objects for broadcast are tied directly to the rollout of ATSC 3.0, and since we won’t see a candidate standard for it until 2016, audio objects for broadcast are a technology of our future rather than our present. The work on this is so current that it was just a month ago (Dec. 5, to be exact), that the ATSC issued a Call for Proposals for ATSC 3.0 Audio Systems, with initial complete system submissions due by Jan. 12, 2015.

It appears that whatever the audio system ends up being in ATSC 3.0, it will be a complete solution from a single company as opposed to a system with technology sourced from many companies. Needless to say, we won’t see audio objects delivered via broadcast in the home for quite some time.

Immersive audio, however, has taken off in a huge way, especially in cinema with the release of films in Dolby Atmos and Auro 11.1 formats. With the inevitable Blu-ray and streaming releases of immersive films to consumers, we will undoubtedly see additional speakers, immersive sound bars and sound frames from a variety of manufacturers cluttering living rooms across the country in the very near future.

# 3: LOUDNESS MANAGEMENT FOR MOBILE, ONLINE DELIVERY—HALF CORRECT
Mobile and streaming is a bit of a conundrum since the devices used to access the content over the air and over the Internet can be the same, though different technologies in the device get used for each.

During a trip to South Korea last year I learned that essentially every mobile phone there comes with unlimited data; that watching television on phones, while riding the subway or driving a vehicle, is something everyone does; and that an awful lot of the phones have an antenna to receive over-the-air DMB television broadcasts.

Compare that to how people use their mobile phones to watch television in the United States, where the majority of viewing seems to be Internet streaming with very little obvious viewing of over-theair broadcasts (based on my observations from the daily commute).

With the big cellular providers making handsets with receivers available and accessory manufacturers providing plug-ins and add-ons for tablets and other devices, there’s no reason people can’t watch broadcast television while they’re on the go, but I still wonder how many people are actually doing so in the United States.

Of course, one big problem with television on the go, whether broadcast or streaming, is that external environmental noise means dynamic range of the audio must be kept to a minimum and loudness management is critical.

On Jan. 30, 2013, the ATSC released their recommended practice A/154:2013, which specifies –14 LKFS as the target loudness level for audio content. This means that a pretty serious loudness practice already exists for mobile television delivery. However, we still have nothing solid for streaming Internet delivery loudness that I’m aware of.

NPR conducted a study on this in 2013 and I’ve been taking some content measurements— both of which we’ll cover in another column—but the results leave me wondering whether this will be the next battleground of consumer audio complaints as viewing of streaming content increases.

THE MISSING PREDICTION
I’m still kicking myself for omitting audioover- IP and AES-67 adoption as an important technology for broadcast audio in 2014, possibly the most important one, in fact. I simply focused too closely on the other predictions and ran out of room and left it out even though I already had plans to begin implementing the technology myself.

Obviously AoIP took off last year with lots of AES-67 compatibility announcements, culminating with a very successful AES-sponsored plugfest in Munich.

After a bit of actual experimentation with AoIP products I found that they behaved pretty much as I expected with high-quality audio, but there were some discovery issues when connecting devices from different manufacturers together, even when using the same AoIP technology. Still, I have high hopes for AoIP and think adoption will continue to escalate this year.

As you can see from this analysis of my 2014 predictions, my crystal ball is on the fritz, so either take my predictions with a grain of salt or just wait awhile, because I have the feeling that all of them will eventually come to pass—my timing is just a bit off.

Jay Yeary is a broadcast television engineer specializing in audio. He can be contacted via TV Technology.

The CALM Act is nothing new, especially to those who have been working on loudness management for years. The general assumption is that everyone “gets it” now, yet I continue to encounter others who don’t fully understand the rule and find themselves floundering with aspects of implementation, typically with measurement. In this column, we’ll look at how to measure content by delving into the official documents of the FCC Report and Order 11-182, FCC Order and Further Notice of Proposed Rulemaking 13-141, and ATSC RP A/85:2013.

METERS
Measurement of all content must be done with a loudness meter that measures LKFS and that preferably uses the ITU-R BS.1770-3 algorithm. The FCC R&O states that, “Compliance with the [recommended practice] requires industry to use the International Telecommunication Union Radiocommunication Sector (ITU-R) Recommendation BS.1770 measurement algorithm.” Gating has been added to the newer BS.1770-3 measurement for audio content measuring below −70 LKFS, and it includes a sliding relative gate for content that falls 10 dB below the absolute gated measurement.

This gating is designed to insure that quiet sections of audio don’t lower the overall loudness reading, which should help measured content match more closely. FCC document 13-141 explains it this way; “BS.1770-3 employs ‘gating’ that will exclude very quiet or silent passages of a commercial when calculating the average loudness of that commercial.” 1770-3 was adopted by the ATSC in the 2013 refresh of A/85, and while the FCC currently allows the use of 1770-1 or 1770-3, the newer version will likely become the official version in November 2014.

THE ANCHOR ELEMENT
The anchor element is whatever piece of audio the listener will be most interested in hearing when viewing the program and is critical to measuring content according to A/85. The anchor element will usually be dialog, but it could be music or another audio element if the program is not heavily speech dependent. A/85 defines it as, “The perceptual loudness reference point or element around which other elements are balanced in producing the final mix of the content, or that a reasonable viewer would focus on when setting the volume control.” In long-form content, the anchor element is to be isolated from other audio elements, measured, and its loudness measurement is considered the loudness value of the content.

MEASURING SHORT-FORM CONTENT
Short-form content is defined in A/85 as, “Advertising, commercial, promotional or public service related material or essence (also termed “interstitial” content). The typical duration is less than approximately two to three minutes.” To determine the loudness value of short-form content, measure the average loudness of the full mix of the content for its entire length. All short-form content is to be measured using this method.

The document does go on to note that this type of measurement could be a problem for wide dynamic range short form content because, “The louder elements of this type of material will increase the loudness measured with a long-term integrated method, and consequently reduce the perceived Anchor Element loudness after normalization. This can cause an unacceptable match to long-form material measured with an anchor-based method.”

No alternative measurement methods are suggested but if loudness-matching problems are experienced with wide dynamic range short-form content, remeasuring using the anchor element measurement method may solve them.

MEASURING LONG-FORM CONTENT
Long-form content is everything that isn’t short form and measuring it is not nearly as straightforward. When it comes to long-form content it’s all about the anchor element. A/85 suggests that during production and post-production the anchor element is to be isolated and measured. If it can be isolated, then a “Representative sample of the Anchor Element,” can be measured instead of the entire program according to A/85.

However, if the anchor element cannot be isolated then it is necessary to measure the average loudness of the entire length of the entire program. For long-form content that is already finished, “A section of the content that is representative of the Anchor Element (typically dialog) should be isolated and measured and reported as the Dialog Level of the long-form content.” A/85 goes on to state that if the anchor element cannot be determined and isolated enough to measure “The loudness of the element of the content that a reasonable viewer would focus on when setting the volume control should be measured and reported as the Dialog Level of the long form content.” If even that isn’t possible then the full mix of the entire program will have to measured.

Measurement during live production is covered briefly in A/85 but the process doesn’t seem clearly defined, though some excellent suggestions are made about mixing using a set control room volume level and focusing on listening with the ears rather than watching meters. Based on information in the document and from experience, a process similar to this should work well: Mix engineers should use a LKFS meter and measure the average loudness of each segment (or full program if continuous) while mixing to the predetermined target loudness for the program. At the same time, the mix engineer may choose to monitor a short-term sliding scale on the loudness meter to keep track of the loudness of the last 3–10 seconds as a guide.

MEASURING DOWNMIX
Measuring the downmix loudness of content has become critical because its loudness value may not match the loudness value of the surround original. Whether the loudness of the downmix and surround version of content match is dependent on where elements are placed in the soundfield. For example, placing the same source across all front channels can boost the downmix loudness by several dB, which means it may no longer match the loudness of adjacent content.

This is an extremely condensed version of how to measure content according to CALM but I hope it makes measurement a little bit clearer for anyone having trouble with it. A/85 and the FCC documents can be a bit daunting, but they contain valuable information that is worth the time you’ll spend reading through them.

Jay Yeary is a television audio engineer who spends his days working for a large media corporation. He can be reached through TV Technology or via Twitter at @TVTechJay.

File-based loudness processing, as one might expect, operates on audio files, either standalone, or extracted from an audio/video file such as MXF. The strength of a file-based processor is that it can gain foreknowledge about an entire audio file (or segment)—start to finish—before doing any processing. Because of this, file-based processing could potentially be less intrusive than its real-time counterparts.

Typically, file-based processing happens in multiple passes. First, the audio signal is analyzed, then—based on preset rules—the processor determines what type of functions or operations is needed and then applies them. Depending on the adjustments needed, further analysis and processing steps may occur in an iterative fashion, to arrive at the final result. While this may sound time-consuming, typical processing times are faster than real time. What kinds of measurements and processing are typical of file-based loudness processors?

DEFINED LOUDNESS TARGET
The first is fairly obvious—loudness. Adjusting the audio signal to reach a defined loudness target is fairly straightforward for file-based loudness processors. Unlike a real-time processor, which effectively rides gain throughout, a file-based processor inserts either attenuation or gain. if it’s needed, to reach the target loudness. This is done after performing a loudness measurement on the file, per ITU recommendation ITUR BS.1770-3, “Algorithms to measure audio programme loudness and true-peak audio level.”

Fig. 1: Example of a file-based workflow that includes loudness measurements and adjustments, and true peak limiting for the AudioTools family of products (Courtesy of Minnetonka Audio Software, Inc.)

This single gain shift (scaling factor) doesn’t change the dynamic range. “It’s like adjusting the gain control on a fader and leaving it alone for all of the content,” said Bob Nicholas, director of international business development for Cobalt Digital in Urbana, Ill.

In addition to loudness, ITU-R BS.1770-3 describes how to measure another parameter, true peak level. Both file-based and real-time processors can provide this measurement. According to ITU-R BS.1770-3, “true-peak level is the maximum (positive or negative) value of the signal waveform in the continuous time domain; this value may be higher than the largest sample value in the 48 kHz time-sampled domain.”

If only the sampled peak value were used, problems such as inconsistent peak readings, unexpected overloads, and under-reading and beating of metered tones could occur. Again from ITU-R BS.1770-3: “The problem occurs because the actual peak values of a sampled signal usually occur between the samples rather than precisely at a sampling instant, and as such are not correctly registered by the peak-sample meter… [The] use of a true-peak indicating algorithm will allow accurate indication of the headroom between the peak level of a digital audio signal and the clipping level.”

DYNAMIC RANGE CONTROL
File-based processors can be used for other related functions as well. One example is dynamic range control (as with the AERO. file option for RadiantGrid or the Wohler loudness appliance solution). Another is measuring and controlling maximum short-term loudness, maximum momentary loudness, loudness range, and dialog level (as with Minnetonka’s AudioTools family, which includes AudioTools Server, AudioTools FOCUS and AudioTools Loudness Control for Harmonic ProMedia Carbon, for another example.)

Simply scaling an audio file, even though it meets a loudness target, may not be enough to stop viewer complaints, if dynamic range remains wider than their systems can handle, as Tim Carroll, Telos Alliance chief technology officer and Linear Acoustic founder, pointed out. That’s the reason for adding dynamic range control to loudness processors. For a theatrical release movie, for example, dynamic range may need to be narrowed to make it a better fit for TV, while a sitcom may not need much, if any, dynamic range adjustment.

File-based processors are capable of making a variety of measurements to determine how to adjust the final output to reach a predefined target. This can often be an iterative process, as one adjustment may affect another parameter. Fortunately iterative processes are well-suited to software-based products. If the target isn’t reached after a certain number of attempts, the processor can send out a notification for human intervention.

File-based loudness processing is typically just one part of an overall file-based ingest or quality control workflow that can include audio up or down-mixing, Dolby E decoding and encoding, metadata adjustment, channel assignment detection and conforming, watermarking, pitch and time control, sample rate conversion, channel management (muting, copying, reconfiguring, replacing), and third-party functions and integration, according to Oliver Masciarotte, director of customer experience at Minnetonka Audio Software.

Fig. 2: Example of a more complex file-based workflow that includes multiple languages, program correlation and channel order verification, downmixing, loudness measurement, processing and peak limiting for the AudioTools family of products (Courtesy of Minnetonka Audio Software, Inc.)

As an example, the AudioTools family can integrate with Telestream Vantage and Harmonic ProMedia Carbon. File-based processing is also amenable to complex automation, according to Masciarotte.

The audio functions can occur alongside any video file-based functions such as transcoding, aspect ratio, standards conversion or quality control.

BRANCHING AND ITERATIVE WORKFLOW
Branching and iteration are keys to efficient and flexible workflows in file-based processors. Let’s look at a couple of workflow block diagrams for AudioTools to see how this works.

Referring to Fig. 1, start at the left side of the block diagram, where the audio essence is extracted from an MXF file. The audio is then checked for the presence of Dolby E. If Dolby E is detected, then the channels are first decoded to PCM before being sent to the measurement and loudness normalization stages. According to Masciarotte, loudness measurement and control, for the most part, needs to happen with PCM (pulse-code modulated) digital audio signals.

While not shown in Fig. 1, the workflow could be set up with another branch to check if the loudness meets the required target. If “yes,” the signal would continue on to the next stage, but if not, the audio channels would be subjected to further loudness level adjustments and measurements.

After the loudness adjustment sections, the workflow checks to see if the signal needs to be converted to Dolby E. Depending on the answer, different true peak limiting is applied. If encoding is required, it happens after the true peak limiter, and the signal gets re-wrapped into the MXF file.

Fig. 2 shows a more complex workflow that includes multiple languages, program correlation, channel order verification, and downmixing, in addition to loudness measurement and processing and true peak limiting.

With software-based systems, workflows such as these are defined according to each customer’s specific requirements. According to Masciarotte, these types of file-based systems can be modular to some extent, scaleable, and easily interoperable across WANs, MANs, LANs and SANs. The file to be processed can be local or remote depending on the system.

Some IT knowledge is typically needed to set these up and to ensure a good user experience.

Mary C. Gruszka is a systems design engineer, project manager, consultant and writer based in the New York metro area. She can be reached via TV Technology.

The year 2013 was certainly an interesting one with the rise of 4K television, the introduction of immersive audio and with CALM Act complaints finally trickling down to broadcasters. Whether this year will be as surprising as last year is anyone’s guess, but there are a few topics I think will be the big stories in television audio this year.

REFINEMENT OF THE CALM ACT
The FCC will continue to monitor and make adjustments to the CALM Act in the coming year, based on consumer complaints and provider data. The legislation still only targets loudness of commercials and not other programming, even though managing loudness across all content is the only way to provide consistency to the listener.

The fact that the FCC continues to receive complaints about loud commercials is partly due to confusion in the wording of the act; partly due to the complexity of the issue; and partly due to the fact that the LKFS measurement is not perfect.

On Nov. 1, 2013, the FCC issued a “Notice of Proposed Rulemaking” that says they are going to adopt A/85:2013 into the CALM Act. This is peculiar because many broadcasters have already started using A/85:2013.

This new notice by the FCC states that broadcasters should continue using the 2011 version of A/85 until the new rule is adopted, which means that broadcasters using the 2013 revision are actually not in compliance. The notice then waives the requirement to use the earlier version for anyone that already adopted A/85:2013. Is it any wonder that content creators and broadcasters are confused?

There is also confusion over exactly how to measure content, even though A/85 spells it out as clearly as it can. Many times the material is to blame, with some commercials having non-traditional mixes (10 seconds of outdoor ambience with no voiceover), or the dramatic pause-for-effect prior to a loud commercial. Content like this not only complicates measurements, but it can also slow down the process of getting it to air.

Then there is the LKFS measurement itself, on which this entire house of cards is based. The measurement is not perfect, which is why it is constantly being improved, but some consider it the best tool the industry has come up with so far to measure loudness in a manner that approximates what humans hear.

There are some dissenters that think the LKFS measurement has serious problems, but it has one thing that alternative measurements don’t. It is the measurement required by law. Obviously, there are still some issues with CALM, so expect to see movement on it this year.

AUDIO OBJECTS, NOT IMMERSIVE AUDIO
There is a lot of talk right now about immersive audio, primarily because 4K video seems to be taking off and immersion is the audio industry’s contribution to that format. Delivering immersive audio to the home will likely require new content creation workflows; new delivery methods; new equipment for creator, broadcaster and listener; new metadata authoring; and more speakers in the living room.

While all of this would be a shot in the arm for audio manufacturers, the average home listener may find little benefit from it, but many complications. However, there is one part of immersive audio that could provide great benefits to the professional and consumer alike, and that is the use of audio objects.

Audio objects are additional channels of audio that can be made up of just about anything, from individual sounds to groups of sounds, to mixed channels of sounds. They were initially conceived as a way to augment surround mixes and deliver specific sounds to specific additional speakers, just as Dolby Atmos does in theaters.

The true power behind audio objects comes from their ability to act as replacement elements for existing elements in the primary mix. It’s similar to having more than one hundred mix minuses from which a completely new mix can be constructed. This could be especially useful for multilanguage content delivery, with a secondary language audio object taking the place of the primary language audio object. Music and sound effects replacement are other targets for this technology.

Rep. Anna Eshoo (D-Calif.), co-sponsor of the CALM Act With expanding worldwide distribution of content, along with increased scrutiny by attorneys and rights-holders, audio objects seems to be a technology whose time has arrived.

LOUDNESS MANAGEMENT FOR MOBILE, ONLINE DELIVERY
Finally, there is the area of loudness management for the countless personal and Web-connected devices in use. Phones, tablets and streaming appliances are like the new Wild West when it comes to audio. Device outputs run the gamut from tiny speakers, headphones, HDMI, optical and unbalanced phono among others, and each one delivers a different user experience. Some of those user experiences occur in horrific listening environments too.

The one thing all of these devices have in common is the lack of standardized loudness management for streaming and broadcast content. Playing a movie from iTunes on a device, and then changing to another movie or television show in the same application does not guarantee the audio level will be the same, or even close. Watching a streaming service such as Netflix or Hulu can deliver an even worse audio experience, with many commercials and bumpers being significantly higher in loudness than the main content.

Mobile broadcasting has a bit of a head start in this area after seeing similar work done for the CALM Act, and work is currently being done to develop a loudness target for mobile. Still, with more consumers using streaming and personal devices, the complaints are bound to make it to the FCC’s ears.

Hopefully the industry will act on loudness management for streaming and personal devices before the government decides to force it through legislation.

That’s the short list of issues that I think could become a bigger part of the audio-for- television landscape this year. We’ll know in January 2015 how big these topics really were.

Jay Yeary is an audio engineer currently working with the engineering department of a large media company. He is not a professional prognosticator, but is willing to play one on TV.