LOUDNESS MONITORING AND CALM COMPLIANCE (UNFOLDING EVENTS) Jim Welch. IneoQuest Technologies

Transcription

1 LOUDNESS MONITORING AND CALM COMPLIANCE (UNFOLDING EVENTS) Jim Welch IneoQuest Technologies

2 Topics What s the issue? What s the history? What are the new rules? What are the key concepts? What are the loudness management options? This presentation is for informational purposes only and does not constitute legal advice. Nothing contained herein should be used as a substitute for the advice of competent legal counsel.

3 What s the issue? Viewer complaints about loud commercials led the US Government to pass the CALM Act (Commercial Advertisement Loudness Mitigation) CALM directs the FCC to make rules designed to prevent TV commercial ads from being transmitted louder than the programs they accompany CALM specifies that the rules apply to TV broadcasters, cable operators, and other MVPDs [Multichannel Video Program Distributors] (cable and telco operators, direct broadcast satellite services, and OTA broadcasters)

4 Unfolding Events December 15, 2010 CALM Act signed into law FCC has one year to issue formal regulations on what MVPDs will be required to do to conform, how MVPDs can demonstrate compliance, define enforcement penalties, and logistics Directs FCC to incorporate the ATSC* A/85 ATSC Recommended Practice: Techniques for Establishing and Maintaining Audio Loudness for Digital Television into rules and make it mandatory as it concerns the transmission of commercial advertisements by MVPDs MVPDs will have one year to comply with the regulations (December 15, 2012) *Advanced Television Systems Committee

5 Unfolding Events May 27, FCC released Notice of Proposed Rulemaking (NPRM) on CALM implementation /db0527/fcc-11-84a1.pdf Extended Reply Comments to August 1, 2011 Requires MVPDs to manage loudness on commercials Solicits inputs on possible compliance issues Allows for a one-year waiver (possibly renewable once) for MVPDs who can show financial hardship to implement rules

6 Unfolding Events ATSC issued new versions of A/85 in May and July 2011 adding: Annex J (Requirements for Establishing and Maintaining Audio Loudness of Commercial Advertising in Digital Television When Using AC-3 Codecs) Annex K (Requirements for Establishing and Maintaining Audio Loudness of Commercial Advertising in Digital Television When Using Non-AC- 3 Codecs)

7 A/85 Annex J Requirements for Establishing and Maintaining Audio Loudness of Commercial Advertising in Digital Television When Using AC-3 Codecs Annex J contains all the courses of action necessary to perform effective loudness control of digital television advertising. when loudness of short form content (e.g., commercial advertising) is measured, it be measured in units of LKFS including all audio channels and all elements of the soundtrack over the duration of the content. it is vital that the loudness match the dialnorm setting of this inserted AC-3 audio stream (See A/85 Annex J)

8 A/85 Annex K Requirements for Establishing and Maintaining Audio Loudness of Commercial Advertising in Digital Television When Using Non-AC-3 Codecs Annex K contains the courses of action necessary to perform effective loudness control of digital television advertising when using non-ac-3 audio codecs. It is vital that the delivery channel operate at an Operator-selected loudness target value (as measured in units of LKFS) for content on the channel. It is vital that, when loudness of short form content (e.g., commercial advertising) is measured, it be measured in units of LKFS including all audio channels and all elements of the soundtrack over the duration of the content. (See A/85 Annex K)

9 A/85 Annex K Requirements for Establishing and Maintaining Audio Loudness of Commercial Advertising in Digital Television When Using Non-AC-3 Codecs In the case of insertion of short-form content (e.g., commercial advertising), it is vital that the loudness, measured as per section K.4, of the inserted short-form content match the delivery channel s loudness target value within +/-2 db. (See A/85 Annex K)

10 Canada s CRTC Loudness Rules Sept. 2011: CRTC announces Broadcasting Regulatory Policy CRTC plans to publish proposed amendments to the appropriate regulations for comment by the end of 2011 Broadcasters and Television Service Providers must comply by Sept, CRTC directs broadcasters and providers to adopt ATSC A/85 Recommended Practice

11 AC-3 Advances Audio Quality Dolby Digital Multichannel audio (AC-3) provides a much improved dynamic range capability 32 times the dynamic range of NTSC Analog TV -- and is much better able to preserve audio integrity from the program creator to the listener. Goal should be to preserve the quality advantages of digital audio not for an MVPD to compress and process the audio and lose the improved quality of advanced digital audio to avoid loudness issues. Ensure that the program source loudness is correct from the content provider. This means that loudness is measured per A/85 and ITU-R BS.1770 using LKFS units and its Dialnorm metadata matches the measured loudness.

12 AC-3 Dialnorm AC-3 bit stream carries a number of parameters (metadata) that allow the decoder to reproduce the encoded audio according to the parameters set by the program creator and by the listener based on his equipment and environment. (Examples are channel mode, LFE channel, line/rf mode, downmix levels, room type, dialogue level (Dialnorm), etc. The Dialnorm parameter is AC-3 metadata that helps in matching reproduced audio volumes when switching between audio program sources. It is used in the decoder to adjust and normalize the reproduced audio level up to 30 db

13 AC-3 Loudness Measurement ITU-R BS.1770 specifies how to calculate loudness for a multichannel audio program in units of LKFS (Loudness K-weighted relative to Full Scale) representing perceived program loudness See: Recommendation ITU-R BS (03/2011) Algorithms to measure audio programme loudness and true-peak audio level

14 AC-3 Loudness Measurement ITU-R BS introduces measurement gating to exclude quiet periods from the loudness measurement. Gating better reflects human perceived loudness. See: Recommendation ITU-R BS (03/2011) Algorithms to measure audio programme loudness and true-peak audio level

15 A/85 Golden Rule for AC-3 The measured Loudness of a program (in LKFS) should match the value of Dialnorm (Action movie loudness example) Loudness may normally vary widely during a program A/85 specifies measuring loudness over the duration of the content

16 AC-3 Loudness Monitoring Continuous per-program archiving of measured loudness allows quick sorting for offenders and content provider scorecard preparation

17 A/85 Golden Rule for AC-3 Drilling into a 15 minute interval for more detail identifies an offending commercial: Off-air Loud commercial example

18 AC-3 Loudness Monitoring

19 Loudness Demos Same program with different dialnorm values Different programs sound different but both comply to RP dialnorm behavior since dialnorm derived from entire program

20 Does my plant conform? Proposed Rules in NPRM for MVPDs: Responsible for loudness for all commercials Responsible regardless of whether AC-3 is used Compliance to A/85 and its successors mandatory Safe Harbor : Use a loudness measurement device, loudness processing device, ensure content suppliers deliver compliant content Other solutions than Safe Harbor are acceptable

21 Does my plant conform? Proposed Rules in NPRM for MVPDs: [Safe Harbor] A cable operator or other multichannel video programming distributor that installs, utilizes, and maintains in a commercially reasonable manner the equipment and associated software to comply with ATSC A/85 shall be deemed in compliance with this section. Proposed consumer complaint procedure to enable consumers to file complaint and MVPDs to demonstrate compliance in response to those complaints

22 Does my plant conform? Recognizing that there may be other than Safe Harbor, solutions in response to a complaint, an MVPD may demonstrate that the Golden Rule was met for a target commercial. We believe the ability to make such a showing useful for MVPDs that have means other than Safe Harbor solution. Contractual approach with content providers deemed efficient however MVPDs responsible for noncompliance. If an MVPD is investigated due to complaints, it may be required to provide sufficient records and documentation to demonstrate compliance.

23 Summary CALM act directs the FCC to issue rules on commercial loudness and to make mandatory ATSC s A/85 Recommended Practice Golden Rule: AC-3 Dialnorm should equal program s measured loudness in units of LKFS per ITU-R BS.1770 algorithm Proposed FCC Rules, an MVPD is deemed compliant if they deploy equipment to comply with A/85. Use of other methods are acceptable. An MVPD may be required to provide sufficient records and documentation to demonstrate compliance MVPDs responsible for noncompliance

24 Additional Reading ATSC A/85 ATSC Recommended Practice: Techniques for Establishing and Maintaining Audio Loudness for Digital Television FCC released Notice of Proposed Rulemaking (NPRM) on CALM implementation 011/db0527/FCC-11-84A1.pdf ITU-R BS (03/2011) Algorithms to measure audio programme loudness and true-peak audio level

25 Additional Reading See paper in Expo Proceedings for additional references

26 Thank You! Jim Welch