Last December’s signing of the CALM Act promises to be a boon to home viewers. However, every link in the content chain, from production to ultimate delivery, has been struggling to determine its responsibility – and culpability – in ensuring an end to the age-old issue of advertising that is louder than the programming into which it is inserted.
As a leading provider of advertising, syndicated programming and infomercials, DG finds itself at the nexus between content providers and broadcasters. Senior VP of Satellite & Technical Operations, David Unsworth, clarifies the current status of the CALM Act and the roles of the various players in content creation, aggregation and delivery in ensuring a smooth transition into compliance.
As the largest distributor of commercial advertising in the U.S., DG has a vested interest in ensuring that those ads are compliant prior to their delivery to TV networks, cable networks and individual broadcast stations.
“The best way to address this is at the source – to make sure that ad production is done with the appropriate loudness spec in mind,” Unsworth said. “We do not see DG’s role as the loudness police, but as a distributor of advertising and programming, we are in a unique position to identify and advice on issues.
“We’ve always performed quality control checks on the content we distribute, and we’ve now added loudness measurement to the suite of QC checks we provide.”
DG has also been proactive in promoting a consistent loudness standard among commercial producers, including ad agencies and post houses.
“In the course of educating people on the situation, we found a fairly wide variation of understanding,” Unsworth said. “But because of the very real threat of having those ads rejected, there has been a very quick appreciation for the issue – which is as it should be.”
Currently, the FCC is in the process of finalizing the “rules of the road” for CALM Act compliance. The ATSC recommended practice for loudness standards is already known and well accepted, and the FCC will be defining certain parameters of compliance and addressing related industry concerns with a final Report & Order, to be finalized prior to Dec. 15, 2011.
Unsworth does not expect any major changes when those rules are announced. He does, however, caution that the best path to compliance lies at the head of the production chain.
“If everybody lines up their equipment correctly and starts with compliant source material, then we have a very good chance of maintaining consistency through the whole chain,” he said. “And, that’s the objective.”
DG sees its role as that of a guardian, protecting commercial producers from network rejections. But in the case of non-compliant content, corrections should be implemented by the producers.
“DG has had a longstanding position that we don’t alter any of the audio unless asked to, because we don’t want to change the creative in any way,” Unsworth said. “If a piece of programming is non-compliant, we will notify the producer, since a remix is often preferable to an overall adjustment. We will only make gain adjustments when specifically requested by our client.”
It’s important to note that loudness measurement techniques for commercials are different than those for long-form content. Commercials are measured end-to-end, while for long-form programming, the general methodology is to use a key portion of the audio, typically the dialogue, as a reference.
Achieving a harmonious blend of commercials and programming is the responsibility of the broadcaster. With the vast array of production styles in play, unifying the loudness in programming is a major challenge.
“The CALM Act specifically addresses commercials, but does not address the programming itself,” Unsworth said. “The intent is to balance the loudness of commercials to that of the programs they run in.”
DG will be setting a good example in this area, because its Pathfire service also distributes a lot of syndicated programming to broadcasters. By taking action to loudness-normalize the spots that are inserted into that programming, broadcasters can have confidence that those shows are CALM compliant. Similarly, as the direct response infomercial programming supplied via DG’s Treehouse Media division moves towards digital delivery, it will also be normalized for correct loudness.
When CALM Act compliance does become mandatory, will consumers actually notice a difference? “In truth, probably not,” says David Unsworth. “Many broadcasters and content producers are staking steps in advance of the enforcement phase. Everybody understands the objective, so nobody really has to wait.
“The major networks are taking steps already, either through the adoption of technology to correct the ads they receive, or just strict policies on the loudness variances they will accept.”
Because of steps already being taken, the overall transition should be largely seamless by the time the law takes effect.
“By the time CALM standards become mandatory – Dec. 15, 2012 – it’s likely that most everything will be in place on both the production and distribution sides of the chain,” Unsworth said. “So, it won’t be like a big switch is thrown to make everything better.
“In fact, most national commercials are now being produced to these standards, and things are better already. We at DG like to think we’ve been doing our part to make that happen.”
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