Taming Loud TV Commercials

You've heard them—commercials that jump out from the surrounding program material and force you to dive for the remote to turn the volume down. Loud commercials were a problem for viewers and broadcasters who had to deal with viewer complaints long before the introduction of DTV. Orban offered loudness control in its "TV Optimod" for analog audio. DTV brought 5.1 surround sound, home theater systems and much wider dynamic range, which made loud commercials even more annoying. Efforts are underway on two fronts to provide relief. Congress is working on legislation to make loud commercials illegal, while ATSC, which has been working on ways to measure loudness and to improve loudness control recently announced it is holding a seminar on audio loudness at the law offices of Wiley Rein on Nov. 4.

Congress's attempt to make loud commercials illegal started with Representative Anne Eshoo's "Commercial Advertisement Mitigation Act" or CALM. Introduced as H.R. 1084 [PDF] last February, CALM gives the FCC one year to adopt regulations that provide:

"(1) advertisements accompanying such video programming shall not be excessively noisy or strident; "(2) such advertisements shall not be presented at modulation levels substantially higher than the program material that such advertisements accompany; and "(3) the average maximum loudness of such advertisements shall not be substantially higher than the average maximum loudness of the program material that such advertisements accompany."

These regulations would apply to cable and satellite channels as well as over-the-air broadcasts. Any engineer reading CALM will pick out the problems with its implementation. How do you define "excessively noisy or strident?" Subjectively it may be easy but providing an objective measurement could be difficult. "Modulation levels" meant something in analog TV or radio, but have no relevance in digital signals. ATSC's work on audio loudness could provide the tools needed to measure "average maximum loudness", but arranging commercials so their audio levels match that of the program scene the precedes it seems impossible.

While the final agenda for the 2009 ATSC Seminar on Audio Loudness hasn't been finalized, ATSC says the day-long seminar "will examine the key elements of audio loudness control. The presenters are all audio professionals active in the industry and closely involved in ATSC work relating to broadcast audio. The seminar will include discussions of broadcast audio challenges in the real world, mix room monitoring, and measurement techniques." In the introduction, it notes, "It is important for the digital television system to provide uniform subjective loudness for all audio content. Consumers find it annoying when audio levels vary when changing channels, and when watching a single channel."

See Candidate Standards Amendment No. 1 to ATSC Digital Television Standard (A/53) Part 5:2007 [PDF] and Amendment No. 1 to ATSC Digital Television Standard (A/53) Part 6:2007 [PDF] for information on proposed changes to the method of measuring the loudness of the average spoken program dialog.

I think there is a good chance some form of loudness legislation will make it through Congress. What Senator or Representative would come out in support of loud commercials? An effort like the one ATSC has undertaken will be critical in providing the FCC with the tools they will need to draft rules to comply with an act like CALM.

Doug Lung is one of America's foremost authorities on broadcast RF technology. He has been with NBC since 1985 and is currently vice president of broadcast technology for NBC/Telemundo stations.