You might just call it the storm before the calm.

Over the next several months, cable operators will furiously scramble to prepare for the new Commercial Advertisement Loudness Mitigation (CALM) Act. Passed by Congress last fall and signed into law by President Obama in mid-December, the CALM Act empowers the Federal Communications Commission to regulate the volume of TV spots for the first time, including punishing those who make or run commercials that exceed the new loudness standards.

Under the new law, U.S. broadcasters, content providers, advertisers, cable operators, satellite TV providers, IPTV providers and other multichannel video distributors must all strive to tone down annoyingly loud commercials so that a consistent audio loudness is maintained from program to interstitial material. Those failing this daunting task could face potentially stiff fines.

In particular, the burden of complying with the CALM Act will fall most heavily on the shoulders of cable operators. Unlike TV broadcasters, cable operators will have to monitor the volume of commercials on a large number of channels. They will also have to show that they have taken concrete steps to identify the offending spots, measure their sound levels and turn down the volume on them.

Unsurprisingly, that’s far easier said than done. Currently, most cable operators don’t have an easy way to identify all of the national and local commercials they run on their systems, let alone a way to identify, measure, log and isolate the loudest ones.

Fortunately, a new generation of advanced monitoring systems is enabling cable operators to track down loud TV commercials, measure their sound levels, create program-level audit reports, and then help tone commercials down in the future.

Anna EshooFirst, it’s time for a little background on the CALM Act. The landmark legislation grew out of chronic viewer complaints about eardrum-shattering commercials as analog signals made the switch to the digital format over the past few years. Unhappy viewers have especially griped about the sudden, unexpected jumps in audio volume when programs segue into commercials or when they change the channels on their sets. Vowing to end these abrupt volume changes, Rep. Anna Eshoo (DCalif.) introduced the original bill in the House of Representatives in 2008.

“The country will now get the relief they deserve from the annoyance of blaringly loud television commercials,” Eshoo said after Obama signed the law. “Consumers will no longer need to dive for the ‘mute’ button during commercial breaks.”

Scheduled to take effect on Dec. 15, the law mandates that the FCC adopt the Advanced Television Systems Committee’s recent audio loudness recommendations for digital television, effectively turning the standards-making engineering group into a quasi-regulatory authority. Citing these standards, known as ATSC A/85, the law then directs the FCC to enforce the standards and establish the procedures for assessing fines for violations.

Although the FCC hasn’t formally issued its enforcement regulations yet, the Commission is expected to follow the approach it has used for closed captioning, obscenity and other TV programming regulations. Instead of directly enforcing the law by proactively monitoring TV commercials on all of the different outlets, which would be an impossible task, the agency will likely rely on viewer complaints to discover when violations have occurred. Cable operators will then either have to prove that they complied with the ATSC A/85 recommended practices by showing their programming logs and other documentation, or by showing that they have the equipment to monitor and will shortly comply. If they can’t do either, they will be fined.

The CALM Act does grant waivers of up to two years for hard-pressed small cable operators and broadcast stations if they can show that adopting the regulations would be a financial hardship. But even they must eventually comply with the law.

Figure 1: Relying on dialnorm values... Click to Enlarge

Given these requirements, the law raises a slew of knotty challenges for cable operators and other video providers to overcome. Specifically, cable operators face significant hurdles in identifying, monitoring, measuring and adjusting loud commercials cost-effectively on a grand scale.

First and foremost, cable operators must find ways to discern when dramatic changes in volume occur in TV commercials or programs. It has been challenging to do this effectively in the past.

In fact, since the introduction of digital video technology more than a decade ago, cable operators have either not measured the audio levels of programs at all, or they have just manually measured the audio level of a single program at a time – and often only for a short period of time, usually for other regulatory compliance purposes. As a result, they have mainly used audio measurement tools designed for the single-channel world of broadcasters, not the vast, much more complicated multichannel cable environment.

Figure 2: Time-Based Report Tracking

While MSOs have relied on the “dialnorm” (dialogue normalization) values for Dolby AC-3 digital audio technology to control noise levels, this method is far from foolproof. The problem is that some advertisers and programmers have set the dialnorm values of their content incorrectly at abnormally low levels. As a result, the loudness of certain program segments or commercials can suddenly spike, or viewers can experience dramatic changes in sound levels when switching between channels.

The two screenshots in Figure 1 illustrate what happens when the dialnorm value (dotted line) is set to a constant value before the ad splicing process, but then is changed to a different value for two specific program segments after the ad splicing occurs.

Indeed, as Gary Traver, the former chief operating officer of Comcast Media Center, told CED earlier this year, some dialnorm levels aren’t even close to where they should be. “We talked to a variety of networks and found some were aware and very focused on continuity of levels, while others weren’t,” he said. “Some intentionally set higher variances.”

Figure 3: Statistical reports by the distribution of programs...

Beyond recognizing the inherent limitations of solely relying on dialnorm, service operators face several distinct challenges to complying with the CALM Act.

Chief among these, operators must find ways to determine when commercial spots begin and end in the massive programming lineups they carry. Without this knowledge, it will be difficult for them to determine the time when the commercials are aired, not to mention find those that exceed the acceptable loudness level.

Real-time audio loudness monitoring poses another major challenge for the industry. Cable operators must find ways to keep tabs on the audio levels of multiple commercials and hundreds of channels simultaneously. Such large-scale, realtime monitoring has rarely been carried out before.

Additionally, alert thresholds must be established to stipulate when the loudness alarms should be triggered. If the thresholds are set too low, too high or otherwise incorrectly, they can’t perform as intended and catch the problem. What’s worse, incorrectly set thresholds could result in false positives – incorrectly identifying a commercial with properly set volume as being too loud.

Finally, multiple system operators must employ solutions that are scalable across both their channel lineups and their many cable systems. If the solutions aren’t scalable, then they won’t be very cost-effective either.

Addressing these critical requirements is a new generation of monitoring systems developed specifically to help operators comply with the CALM Act.

One of the defining characteristics of these new monitoring systems is the ability to analyze and report audio loudness using the dB LKFS (Loudness, K-weighted, relative to Full Scale) measurement, which is based on the ITU-R BS.1770 audio standard. The system enables ops to track not just a single program at a time, but hundreds of programs with commercials based on LKFS measurement in real time – automatically and simultaneously.

Another critical capability of these new monitoring systems is to support various audio alert settings and thresholds, as well as to generate various audio loudness reports to satisfy different users and use cases. One major U.S. MSO already uses a monitor with this capability to track audio loudness levels for all of its programs in real time, as well as to generate summary reports.

Figure 4: Especially loud-audio-content... Click to Enlarge

For example, the reports shown in Figures 2 and 3 can be generated in userconfigurable duration from minute- to week-long, and therefore offer cable operators insight into their system and allow them to “proactively” identify and mitigate audio loudness issues across all programs.

Next-generation monitoring systems must also enable operators to identify excessively loud program segments or commercials via alerts and reports, validating viewer complaints and meeting FCC requirements for documentation.

The screenshot in Figure 4 is an example of such reporting. It shows that the mean audio level (solid line) consistently stayed at a much higher level (11 dB louder) than the dialnorm value (dashed line) for an hour-long stretch. The candlesticks in the graph show the audio’s dynamic range – the range of how loud or quiet the audio was.

The system must also enable cable operators to look back historically to determine if any claims or suspicions of loud commercials are valid or not. This information can also help operators find and troubleshoot the root cause of the problem, resolve it and prevent the problem from happening again.

Finally, the monitoring system must maintain all of this important information in its database and then present it in an intuitive fashion. This can save cable operators tremendous time, money and headaches as they gear up to meet the new law’s audit requirements.

In short, the CALM Act will pose some major new challenges for cable operators as they struggle to turn down the volume on loud TV commercials. Operators will have to grapple with audio tracking, measuring and reporting issues they have likely never faced before.

But, with the right type of audio monitoring system installed, cable operators can tackle these challenges head-on and start lowering the volume on those blaring commercials. The key now is to grab the bull by the horns and start putting those solutions in place – right away.