The Time to Plan for CALM Is Now

The road from vague Congressional mandate to something about which engineering staffs actually must worry is long, and it's easy to continually shuffle the topic to the bottom of the priority list. Now, however, is the beginning of the end game on The Commercial Advertisement Loudness Mitigation (CALM) Act, and operators are advised by insiders to begin listening up.

Subscribers have long complained about commercials that are too loud. CALM, which can be perceived as an easy win for politicians -- neither Republican nor Democratic voters like pitch men to scream at them at twice the volume of the show they are watching -- was passed by Congress in early December of last year.

The CALM Act directs the FCC to create rules that rely to a great extent on the A/85 recommended practices from the Advanced Television Systems Committee. The FCC plans to vote on those rules on Dec. 15. Since these things normally are hashed out by the commissioners and the chairman ahead of time, approval is likely.

Once officially adopted, the new rules will be mandatory in a year's time. Smaller operators could get waivers allowing them a year or two longer to comply. The only option unsatisfied parties would have is a lawsuit, said Ross Lieberman, the vice president of governmental affairs for the American Cable Association.

Lieberman points to one looming issue. Congress instructed the FCC to pass rules that govern only the actions of broadcasters and cable operators. That works fine in the case of local insertion. On the national front, however, it's a bit more complex: The A/85 best practices provide guidance to a wider ecosystem of players, including program originators. Thus, a strict interpretation of the rules could put the onus on cable operators even if the problem lies elsewhere.

Lieberman is confident, however, that Comcast, Time Warner Cable, DirecTV and other big service providers will use their influence to ensure that the programmers don't take advantage. This cooperative spirit, he suggested, could be codified in contracts. Small operators would benefit since they use the same feeds.

Planning Should Begin

Observers say operators need to start thinking about how to approach the issue both to satisfy the FCC and also to finally tame inconsistent volume issues that annoy subscribers, which may be a more important goal.

The machinations of the FCC and Congress come at a time when monitoring technology is evolving rapidly. In the past, network owners only were limited to the  monitoring of individual channels on a sporadic basis. The rush of new technology now makes it possible to monitor as many channels as necessary and to so continually, in real time. The results can be stored and presented in whatever format necessary to important partners -- such as programmers who are being asked to clean up their audio.

The certainty that the FCC is about to release rules on loudness is driving the industry to take a good look at the state of its audio, which is a good thing in an increasingly competitive environment. Even better, enough is known about the new rules that vendors' hardware and software can be made to comply with the new rules via firmware and software updates and upgrades.

All that is positive. The bottom line, however, is that the industry better start moving. "I think the broadcasters are ahead of the cable operators today," said Volicon's Asebrook. "The cable operators at this point have to start paying closer attention. It takes time to look at the options, get all the equipment in place and train people. The process takes time. We will see over the next year cable operators get more into this issue, I think."

Vendors are not delaying, however. It appears that operators have a good selection of products from which to choose.

  • Volicon Observer version 6.0, according to the company's Senior Director of Product Marketing Mike Asebrook, logs data on a 24/7 basis and stores it for a year. It provides a configurable overlay of visual loudness measurements. Alerts can be sent via email or text if the system is working outside of pre-established parameters.

  • Tektronix has two products to combat loudness. Sentry is available now and Sentry Assure is set for introduction. Steve Lieu, Tektronix's vice president of video network monitoring said both offer audio loudness measuring capabilities and were specifically designed with the CALM Act in mind.

  • Trivini Digital also is in the mix. Ralph Bachofen, the company's vice president of sales and head of marketing, said StreamScope is an MPEG analyzer that looks at the entire transport stream, not just the header. StreamScope, he said, can be updated via a software download once the precise FCC rules are known.

  • Miranda offers Axino. Mitch Askenas, Miranda's director of business development, Axino can simultaneously monitor hundreds of channels and correct those that "stray out of spec."

Carl Weinschenk is the Senior Editor for Broadband Technology Report. Contact him at

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