A Guide to CALM Act Compliance

Understanding Loudness Control and its Efficient

Integration Into File-Based Video Workflows


“The CALM Act is intended to spare viewers the annoyance of constantly adjusting the volume on their

TVs to compensate for the significantly higher audio level of commercials”



For most of television’s history, viewers have complained about big differences in volume between commercials and the surrounding programming. But it’s only in recent years that lawmakers—spurred by public pressure and newly-refined techniques for quantifying apparent loudness—have taken concrete action to address the issue with enforceable regulation. In the United States, that action is the Commercial Advertisement Loudness Mitigation (CALM) Act of 2010, which came into effect December 13, 2012.

Like its counterparts in other countries, the CALM Act is intended to spare viewers the annoyance of constantly adjusting the volume on their TVs to compensate for the significantly higher audio level of commercials. The law holds broadcasters responsible for ensuring volume consistency across all program components. Those failing to meet this responsibility may incur significant financial penalties imposed by the Federal Communications Commission (FCC).

While the law is simple enough in concept, the devil is in the details. In particular, three main aspects of the issue must be well understood in order to comply intelligently and efficiently with the requirements of the new law:

• How does the law envision that apparent loudness will be quantified and compared (e.g. A/85, BS1770, EBU R128, and Dolby Dialog Detection)?
• What are the most effective loudness control techniques available to ensure compliance with the law?
• What are the most efficient approaches to integrating loudness control into the workflow of enterprises—such as broadcasters, cable MSOs, and satellite providers—that handle a significant quantity of video content?

By providing an overview of the issues above, this document offers guidance on coping most effectively with the changes required to comply with the CALM Act.

The CALM Act and ATSC A/85

The CALM act directed the FCC to introduce regulations requiring any broadcast station, cable operator, or other multichannel video programming distributor (MVPD) to control the loudness of the commercial advertisements that accompany their programming.

The law mandates that the application of loudness control shall conform to the recommended practice developed by the Advanced Television Systems Committee (ATSC) and codified as RP A/85, which is the ATSC’s Recommended Practice Techniques for Establishing and Maintaining Audio Loudness for Digital Television.

Because the CALM Act mandates conformance with A/85, understanding compliance begins with under- standing the ATSC’s recommended practices.
The relevant portions of A/85 deal with these main issues:

• Loudness measurement — what techniques are to be employed to determine the loudness of a given clip (commercial or programming)? What is to be measured, and how?
• Loudness adjustment — if a given commercial clip does not have the desired loudness, how is the loudness of the commercial best adjusted?
• True peak — what is the impact of loudness correction on the maximum level of the program?

Defining the Anchor Element

The starting point for understanding A/85 loudness- measurements is to define what is to be measured. A/85 recommends that loudness measurement be done only on the “Anchor Element” of the audio, which is defined as the perceptual loudness reference point of the content.

According to A/85, in most programming, most of the time, the perceptual loudness reference point is the dialog. This reflects the fact that people are generally more sensitive to loudness of speech than to the loudness of other elements in the audio. Because speech is critical to our understanding what is happening on screen, it’s more annoying to be unable to hear speech clearly (because it’s too quiet, for example) than to be unable to clearly hear background music or sound effects.

A/85 also allows for an element other than dialog, such as music, to serve as the Anchor Element for a loudness measurement if that element is deemed more appropriate in the context of a particular piece of content. In such a situation, the Anchor Element shall be the element that “a reasonable viewer would focus on when setting their volume control.”

Loudness Measurement Techniques

To be valuable in combating the problem of inconsistent loudness, the technique used to measure loudness must correspond to human perception of what is and is not loud. It turns out that this is largely context dependent, and not as simple as measuring sonic energy at a given instant in time.

“the technique used to measure loudness must correspond to human perception of what is and is not loud”

Figure 1a — Peak level measurement.
Figure 1a — Peak level measurement.

Loudness measurements have traditionally been based on the VU (volume unit) and Peak Level meters, technologies that originated in the analog audio world and were carried over into the digital domain. Peak Level indicates the moment of highest voltage, which translates into the greatest sound pressure level (SPL) when the program is reproduced via a loudspeaker.

While peak level is a useful measurement for preventing distortion in electronic circuits (e.g.

Figure 1b – Adjusting overall level based on  peak level may make some parts of the program too quiet.
Figure 1b – Adjusting overall level based on
peak level may make some parts of the program too quiet.

clipping), its utility in predicting the human perception of loudness varies greatly depending on its relationship to the average level of the program. The closer the average level is to the peak, the louder the program will seem to be. Conversely, isolated peaks in an otherwise quiet program (low average level) don’t create the perception of overall loudness. Thus, as illustrated in Figure 1, if the peak level is much higher than the average level, then overall volume adjustments based on peak may make some sections of the content unacceptably quiet.

A new approach to loudness measurement

Recognizing the problems inherent in a simple peak- based assessment of program level, the International- Telecommunications Union (ITU) developed an alterna- tive specification for loudness measurement. ITU-R BS.1770 was first published in 2006 and subsequently revised as 1770-1 (2007) and, more recently, 1770-2 (2011). The Calm Act refers to A/85, and A/85 specifies BS.1770 (specifically referencing BS.1770-1) as the source of its loudness measurement techniques (1770-2 did not exist at the time A/85 was finalized).

Figure 2 – Average loudness measurement.
Figure 2 – Average loudness measurement.

So BS.1770-1 currently serves as the yardstick by which U.S. television programming will be evaluated for CALM Act compliance.

Under BS.1770, loudness is measured by integrating the weighted power of the signals in all of the program’s audio channels (except, in 5.1 audio, the Low Frequency Effects channel). The result of a BS.1770 measurement is, under A/85, expressed using LKFS, which is defined as “loudness, K-weighted, relative to full scale, measured with equipment that implements the algorithm specified by ITU-R BS.1770. A unit of LKFS is equivalent to a decibel.”

The drawback of BS.1770 as originally conceived is that it measures average loudness over the entire length of content. This may be fine if the loudness is fairly consistent over time. If not, a quiet section of content may, as illustrated in figure 3, bias the average level so that it measures as acceptable despite having some sections that are unacceptably loud.

Measuring a dialog sample

The drawbacks of the average measurement technique- described in BS.1770 help explain why the A/85 concept of the Anchor Element is so important in obtaining valid measurement results. While BS.1770 envisions that a measurement will be taken for the full duration of the content, A/85 recognizes that in practice there are situations that may be either difficult or misleading (as shown in Figure 2). So it allows instead the measurement of a representative sample of the Anchor Element, and presents guidelines for choosing that sample in different situations (live content, finished long-form content, short-form content, file-based content, etc.).

In practice, implementation of Anchor Element measurements involves identifying—either manually or using automated “dialog detection” or “speech detection” techniques—those areas of the program where dialog is predominant. The BS.1770 measurement is then applied only to sections of content that contain dialog. This generally removes measurement bias, as dialog is generally not very quiet, and it also acknowledges the fact that people are particularly sensitive to dialog levels.

Useful as it is, dialog detection has some potential weaknesses. Dialog detection algorithms vary in their accuracy, and while algorithms from industry-leading companies such as Dolby are remarkably accurate there is currently no completely foolproof method of automated dialog detection. Further, while the vast majority of content has a significant amount of dialog, applying dialog-based measurements to content without much dialog may not give a good indication of subjective loudness. A fall-back plan is generally required for such content.

Gated Measurements

Measuring a dialog sample is not the only way to avoid the potentially misleading results that can come from measuring across an entire program. An alternative approach is to use a measurement gate. First put forward as part of the European Broadcast Union’s R128 standard, this technique was later added to BS.1770-2. Since A/85 has not been revised to reference 1770-2, it is currently unknown whether measurements made using this technique are considered by the FCC to be consistent with the requirements of the CALM Act.

Gated measurement works by analyzing the loudness of the audio in short sections. The loudness value of a given section will count toward the overall

Figure 3 - Gated Loudness measurement.
Figure 3 – Gated Loudness measurement.

loudness value of the program only if that section measures above a certain threshold (the “gate” value).

The gate effectively excludes quiet periods from the final measurement. Figure 3 shows a gated measurement applied to the same signal as the ungated measurement from Figure 2.

Opinions vary as to whether gated measurements or dialog measurements are more effective in producing loudness measurements that track the perceptions of the typical TV watcher. The ideal may be a hybrid of both approaches, with dialog measurement being used for content that has a high proportion of dialog, and gated measurement for content that doesn’t have much dialog.

Neither gated measurement nor dialog measurement is explicitly mandated by A/85, but since A/85 envisions that dialog will normally be the Anchor Element it could be argued that the dialog method more closely reflects the intent of the current standard.

There are many in the world of broadcast audio, however, who feel that automated dialog detection is particularly inaccurate or inappropriate for short form content, such as the 30 second commercials that represent the majority of content covered by the CALM act. It is quite likely that, at some point, use of gated measurement will be recommended as best practice for such content. So the wisest course for now is to avoid getting locked into a loudness measurement system that supports only one, but not both, of these approaches.

Loudness correction with dialnorm

With the measurement techniques described above it’s possible to identify materials that are likely non-compli- ant with the CALM Act and to quantify the amount of loudness correction needed. To understand how the correction itself is best applied requires familiarity with “dialnorm.” dialnorm is a metadata parameter used in a number of audio compression schemes, including the Dolby Digital (AC-3) codec that is part of the ATSC specifications for broadcast television in the U.S.

“…dialnorm is a metadata parameter used in a number of audio compression schemes…dialnorm can be used to standardize program output to a consistent level of dialog”

Carried in the metadata associated with each com- pressed audio stream, the dialnorm value represents the loudness of the dialog in that stream expressed in LKFS as measured with BS.1770 techniques. Because every Dolby Digital decoder is equipped with the ability to adjust the audio output level based on the dialnorm of the content being decoded, dialnorm can be used to standardize audio output to a consistent level.

To see how this works in practice, consider the transition from a television program to a commercial. If the program’s measured loudness dialnorm value is -24 and the commercial’s is -21, the commercial is 3 LKFS louder than the program. The audio decoder corrects this by applying the associated dialnorm value and thus attenuates gain by 3dB for the duration of the commercial, and then removes the attenuation when the commercial ends and the program resumes. The net effect would be to make the apparent loudness of the commercial dialog consistent with that of the program. The concept of dialnorm can be applied in different ways depending on the situation:

• Gain-based loudness correction, also referred to as Fixed dialnorm, involves the enterprise—network, station, or cable operator—settling on a standard dialnorm loudness target and then adjusting the gain of each program and commercial so that its loudness measures at the target value. Fixed dialnorm is the only option for audio signals that do not carry dialnorm metadata, and it removes the requirement for level adjustments by the decoder at the receiving end. The drawback of this ap- proach is that it requires a broadcaster to analyze every piece of content, and to correct any piece whose dialnorm falls outside a predefined Target Loudness standard (typically within 2 dB of -24 LKFS). At a very minimum this correction process requires decoding, adjusting, and re-encoding the non-standard audio content.
• Metadata-based loudness correction, also referred to as Agile dialnorm, is the strategy of measuring the dialnorm on content and simply putting the correct dialnorm value in the metadata of the audio, relying on the decoder at the receiving end to adjust the volume accordingly. This approach has the advantage of allowing loudness to be corrected without decoding and re-encoding the audio, but it assumes that all receivers have to have the ability to adjust level based on dialnorm.

True Peak adjustment

dialnorm provides a valuable framework for loudness- correction, but to be complete an effective loudness control scheme must account for the impact of gain adjustments on other aspects of the adjusted audio stream, including the stream’s absolute maximum amplitude, which is referred to as “true peak.” Referenc- ing Annex 2 of BS.1770, A/85 describes true peak as being measured in dB TP, meaning decibels relative to full-scale (the absolute maximum possible amplitude).

If positive gain is applied to a stream whose true peak is already close to the maximum possible value, the result may be clipping (overload), introducing audible distor- tion into the audio. A/85 recommends a target true peak of -2 dB TP for interchanged audio so that headroom is available to apply some downstream processing without clipping.

Ensuring that loudness-corrected audio complies with True Peak guidelines requires measuring the True Peak of the program and calculating the effect of loudness correction on that peak. A couple of different strategies are available for dealing with situations in which loudness correction would make the true peak too high:

• Reduce the amount of gain applied by loudness correction (or adjust the dialnorm value) such that true peak does not exceed the specified limit. The down side of this approach is that the loudness- corrected content will be quieter than it should be to achieve full loudness correction.
• Apply a peak limiting algorithm to reduce the peak without significantly affecting the overall loudness of the content. This is typically the preferred approach, but in some types of program peak limiting can result in noticeable audio artifacts (e.g. “pumping”).

In addition to loudness and true peak, A/85 also concerns itself with a number of related issues including dynamic range control as well as setup and calibration. These topics fall beyond the scope of this document.

Workflows for loudness control

At this point it should be evident that the CALM Act, while yielding obvious benefit for the content consumer, places an important new responsibility on the content provider, which is to ensure that content is delivered to the consumer with the correct audio loudness and metadata values. While the failure to do so may result in significant penalties, the burden of compliance need not be onerous.

The extent to which compliance is problematic for a given enterprise depends largely on the workflow employed in readying program and commercials for delivery to viewers:

• Facilities relying solely on real-time baseband SDI-based infrastructure will find CALM Act compliance the most difficult. Expensive new hardware will be required at some point in the signal chain to provide the loudness regulation capability. And because real-time devices must work in a single pass, they are unable to analyze an entire piece of content before making level corrections. As a result, audio quality may be compromised in order to achieve regulatory compliance.
• Facilities already utilizing a file-based workflow may well find CALM Act compliance relatively easy and painless. A typical file-based infrastructure already incorporates workflow automation and transcoding systems that route incoming assets for re-wrapping or re-encoding as needed for distribution and archiving. Assuming that such automated process- es have been well implemented, adding loudness measurement and correction to the workflow is a relatively simple matter.

In a well-designed file-based workflow, conformance to A/85 would typically require the addition of only one step, which is the analysis of program loudness (LKFS) and true peak (dB TP). In many settings the workflow may already include some form of audio analysis, in which case the existing analysis methodology need only be conformed to A/85’s recommended practices.

The favored method would be to perform the analysis step on content as it is first delivered to the facility, so that metadata from the analysis is available to down- stream processes. That way, if correction is required it can be applied in an existing downstream workflow step. This approach allows loudness regulation to be added to an existing workflow with little or no additional cost in terms of processing time or additional workflow steps. Once the workflow changes have been made, the process continues to work as seamlessly as before.

Integrated workflow solutions

At Telestream, we have long believed that tight, flexible integration between process steps is the key to maximizing the speed and resource-efficiency of content processing solutions. In a file-based loudness regulation system that is not designed for tight integration, of which there are a number on the market, the overall efficiency of the workflow can suffer as a result.

A vendor that specializes in audio, for example, may provide excellent loudness regulation, but may not provide the necessary format support for video codecs and container formats. This can lead to files having to be re-wrapped or transcoded into a format that the audio correction software can deal with, then transcod- ed again into the intended delivery format.

A tightly-integrated, file-based environment makes it possible to achieve far better quality in loudness- corrected content. Integration facilitates the handoff of analysis metadata, and allows the application of different loudness correction techniques simultaneously as a given piece of content is repurposed for multiple delivery platforms (e.g. broadcast, Web delivery, satellite network distribution). Ideally, a file based system should also be able to choose between measurement methods (dialog detection or gating) based on the proportion of dialog in a piece of content.

calm_figure_transcoding_lastPg JPG

Finally, such a system can provide logging of data about the analysis and correction performed on every asset that passes through. Such logging could prove invaluable if there were a question about compliance with regulations.

The benefits of using a well-designed, tightly-integrated, filebased workflow automation system for loudness correction are sufficient to warrant the introduction such a system into a facility for the first time in response to impending CALM Act enforcement. The cost of a server and software license will frequently compare favorably with the cost of a less-effective hardware solution. The Telestream Vantage platform, for example, combines analysis, metadata transfer, transcoding, and auto-correction into a highly integrated file-based workflow, providing the ideal environment for broad- casters, cable operators, and other multichannel video programming distributors to address CALM Act requirements. Both gated and dialog measurements are included, allowing our customers to choose the methodology that they feel is best suited to meeting their compliance needs.

Vantage is one of the few solutions on the market today that can provide CALM Act compliance in a tightly integrated solution with a choice of loudness measurement options.

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