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TV CALM Act

Brian Bowers said:
So what...are the TV and cable stations now processing their audio much more aggressively, compared to what they used to? Quite frankly, I'm not sure I notice much of a difference.

http://www.fcc.gov/encyclopedia/loud-commercials

The point is actually to process much less aggressively...

The CALM Act requires broadcasters to comply with the loudness-based measurement, which is specified in the ITU BS.1770 document. This is a change from the peak-based requirements in broadcast thus far (in digital TV, that's -9dBFS) to a loudness-based requirement. CALM act specifies -24 LkFS target level (loudness K-weighted according to BS.1770, relative to full scale). There's a also a peak ceiling at -2 dBTP (TP standing for true peak, which is a 4x oversampled peak measurement).

Basically, this change forces all the program segments in broadcast to be matched based on loudness, not on peak level any more. The main idea is to avoid loudness jumps in TV broadcast (in particular in transitions for a movie or a drama to jingles and commercials and vice versa) and resulting viewer annoyance.

Those who process more aggressively are completely missing the picture... They can now process much less aggressively, leave program material with higher dynamic range and maintain a uniform loudness during broadcast. With the loudness-based system, processing more aggressively does not help you, or give you any advantage such as being louder. In contrast, the processed material will not come out louder (as it does with peak-based system) since it's now loudness matched. It only sounds more compressed and lifeless, compared to the less processed, higher dynamic range material. Ideally in the long run, the change might help revert the current tendency to over-process everything, commercials in particular...


Regards,
Goran Tomas
 
Does this rule also apply to analog LPTV stations, especially those on Channel 6 which are acting as FM radio stations?
 
The country can't get its financial house in order, but congress is worried about the volume of commercials.
 
satech said:
Does this rule also apply to analog LPTV stations, especially those on Channel 6 which are acting as FM radio stations?

By my reading, no. Keep in mind that I'm an engineer, not a lawyer.

The CALM Act is implemented for full-power stations as regulation 73.682(c) and 73.8000. What it does is to make compliance with ATSC standard A/85 mandatory.

This standard only applies to digital stations -- from an engineering standpoint it's not possible to apply A/85 to an analog station.

It's implemented as FCC regulations 73.682(c) and 73.8000. These regulations do NOT appear in the list of those incorporated by reference in Part 74. (so by my reading, while it would be technically feasible to apply the CALM Act to *digital* LPTV stations, the rules do not apply it.)
 
The country can't get its financial house in order, but congress is worried about the volume of commercials.

LOL. Ain't that the truth!

How is the audio being treated differently? Are only commercials fed thru a new processor? Have TV stations installed new audio processing? Are there then new audio (modulation) monitoring devices to make sure you're playing by the new rules? Just wondering. I know this is a radio board, but every once in awhile, something related to broadcast TV comes along that sparks my interest.
 
"How is the audio being treated differently? Are only commercials fed thru a new processor? Have TV stations installed new audio processing? Are there then new audio (modulation) monitoring devices to make sure you're playing by the new rules? Just wondering."
A new series of audio management tools and devices have been designed to
accommodate compliance. Orban even offers a fine computer based metering
tool o view and log your compliance. See: www.orban.com/meter
The devices are now not as aggressive as what are used in radio, and adjust
accordingly to the IEC psycho algorithims, 'stead of peaks and such.
The idea was to tone down Billy Mays, but he's gone and others have
taken over the punchy delivery.
 
There is way too much audio processing at the commercial production studios. They want the commercials to be as loud as possible.
Hopefully they will stop their aggressive audio processing.
 
Engineering/Re: TV CALM Act

I did not know until now that LPTV stations don't have to comply. This explains while watching 2 of them last night, KCWQ and KRET in the Palm Springs Ca. area, I noticed the local spots were still blasting at levels far above the network programs and spots.
 
Maybe I'm not seeing the whole picture here (bad pun). Some TV commercial audio is extremely dense. Where as some non-commercial audio is not. From what I am hearing, to me, the commercial audio still sometimes seems louder (as confirmed on my Dorrough loudness metering). And from what I am learned in the past, that would make sense. To me, any audio that reduces the peak to average ratio, will seem louder. Until all TV audio is exactly the same (peak to average ratio), some audio will still seem louder than less dense audio. Am I wrong? I mean how many ways can you measure audio? One's ears are usually the best measuring device. That was why I wondered if TV was now processing (controlling) their audio more aggressively. Before the CALM act took effect, some TV audio, to me, seemed wide open, with lots of dynamic range. Then all of a sudden you get an overly processed (dense) commercial, and of course that is going to seem louder.
 
It's easy to make TV audio dense yet remain in compliance with CALM. I mix tons of audio for TV in pro tools and plug ins like Isotope's Ozone 5 already have presets to get audio into compliance and give the mixer tons of options to tailor the sound. You can easily have very ugly audio yet be perfect legal at 23 or 24 lkfs.
 
Sounds like people will still complain, then.
Glad we have a nice, expensive monitoring and logging system, to CYA (if ya' get my drift).
 
Brian Bowers said:
Maybe I'm not seeing the whole picture here (bad pun). Some TV commercial audio is extremely dense. Where as some non-commercial audio is not. From what I am hearing, to me, the commercial audio still sometimes seems louder (as confirmed on my Dorrough loudness metering). And from what I am learned in the past, that would make sense. To me, any audio that reduces the peak to average ratio, will seem louder. Until all TV audio is exactly the same (peak to average ratio), some audio will still seem louder than less dense audio. Am I wrong? I mean how many ways can you measure audio? One's ears are usually the best measuring device. That was why I wondered if TV was now processing (controlling) their audio more aggressively. Before the CALM act took effect, some TV audio, to me, seemed wide open, with lots of dynamic range. Then all of a sudden you get an overly processed (dense) commercial, and of course that is going to seem louder.

You're basing all your experience on audio that is peak normalized...

What if, instead, audio is loudness normalized? What if you adjust the gain of all your commercials and all other program segments so they are all come out equally loud?

How would then something be louder, when you've just adjusted them so that they are all at equal loudness... How would over processing and further reduction of peak-to-average ratio help you, when at the end you would adjust the gain so that it comes out at the same loudness as all the other stuff?


Regards,
Goran Tomas
 
oldiesstation said:
What we really need is a device that will mute the commercials automatically.Now that would be awesome!!Merry Christmas Everyone...

The next best thing is DVR.

R
 
Brian Bowers said:
How is the audio being treated differently?

At the moment, it's mostly just gain adjusted. In the future, hopefully, it will be produced differently...

Are only commercials fed thru a new processor?

The CALM act targets advertisements in particular, but best results are achieved when all program elements are loudness matched.

Have TV stations installed new audio processing?

Not necessarily, although A/85 complaint processors make things much easier. Existing processors need to be re-adjusted so that they maintain an average target loudness level of -24 LkFS. In most cases that means reduction in output gain by about 6dB (varies), ability to relax the processing and allow more dynamic range, or even the possibility to completely turn off (bypass) processing for material that has already been made compliant in production or ingest.

Are there then new audio (modulation) monitoring devices to make sure you're playing by the new rules?

Yes, there are ITU.BS1770 loudness meters such as Linear Acoustic, Harris, TC Electronic, RTW and others.

Some more Q&A information about the CALM Act is available here.


Regards,
Goran Tomas
 
Label the scale however you want for TV. In the end, you're still dealing with peak and average (loudness) audio. I looked at TC Electronics TV gear. The word "peak" is mentioned many times over and over. Even though the CALM act makes you pay much closer attention to "Loudness", you will still always have a peak to go along with your average loudness level. What I did discover while reading some of this material, which average viewers may not understand, is that average loudness is measured over a certain period of time, not just from a show (wide dynamic range), into a commercial break (little dynamic range). I didn't know that. I never could find what that amount of time was though. So there are still going to be loud parts and quiet parts. I don't see how the average joe is supposed to understand this.
 
Loudness is far more complex than average/peak audio.
Many commercials are equalized to boost the region around 3kHz.
This makes the commercials sound louder because our ears are most sensitive to that frequency area.
There is no guaranteed 'fix' to the loudness problem until the commercial producers stop over-processing their products.
 
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