The FCC's (News - Alert) Commercial Advertisement Loudness Mitigation (CALM) Act mandates that TV commercials aren't allowed to be any louder on average than the shows they accompany. It went into effect on Dec. 13, 2012, and requires that all multichannel video operators, not just cable companies, adopt a set of recommended practice provisions. There are, however, notable operational challenges that TV providers have on their plate when it comes to complying with CALM, stemming from the increasingly complex landscape of video delivery.

“When you factor in adaptive bitrate streaming, which dynamically adjusts IP streams to the available bandwidth, three-screen delivery, and the availability of more and more channels, rapidly detecting faults before users see them becomes more critical than ever,” explained Jim Welch (News - Alert), director of product management at IneoQuest.

Enter real-time, automated monitoring and analytics, which allow operators to be cost-effectively proactive about correcting audio loudness for TV programming and digitally inserted commercials—across thousands of broadcast and IP streams.

 “Operators should look at software packages that do this as a technician that never takes a break and can measure hundreds of feeds, across thousands of households, at the same time,” Welch said. “Meanwhile, longer-term reports that show how well loudness goals are met historically are helpful when answering an enforcement action.”

The way CALM is implemented has to do with audio signatures. “Essentially, they have to follow a golden rule, which says that the loudness of the programming equals the dial norm value—which is a data value transmitted with most U.S. broadcasts,” said Welch. “This is used to adjust, automatically, how loudly the system plays back the content. So the loudness of the content must equal the dial norm value, and if either is off, the playback has problems.”

And pay-TV providers must be prepared to demonstrate compliance—to show that the program pass-through equipment is compliant with the ATSC 85 requirements, and to provide spot-check information. Otherwise, they face potential FCC fines from enforcement actions. But taking a comprehensive approach to quality assurance around CALM addresses more than simply achieving and proving CALM compliance to the FCC—it reduces customer dissatisfaction and churn as well. And, CALM compliance also helps operators to maintain advertiser satisfaction, which is critical to an operator’s business model from a revenue perspective.

In IneoQuest’s (News - Alert) case, CALM compliance is part of a scalable quality assurance system that monitors many network distribution points—video quality overall, closed captioning, audio quality and loudness, across hundreds of thousands of simultaneous channels—there are hundreds of locations in a distribution system. There are also many kinds of transmission: over the air, cable HFC, fiber and so on. Loudness procedures should be part of the overarching metrics that operators use to ensure quality of service (QoS) and quality of experience (QoE) for all subscribers.

“The alternative option across all the channels is to simply use the viewers as the quality assurance mechanism. You wait for them to complain,” he said. “Operators need to realize that there is a need for an automated monitoring and quality assurance system so you can take automated and rapid correction when there’s an issue.”

Welch also noted that, as subscribers install higher-end TVs, the HD audio makes audio levels much easier to discern when there’s out of sync. “That will make non-CALM-compliant delivery more noticeable and more annoying,” Welch said. “Most operators are up against a lot of competition, and you want to make sure that you’re not giving subs a reason to switch.”

Both the CALM act and the actions that operators have taken have already improved loud commercial problems, Welch noted. But in the long run, automated quality assurance is the most cost-effective way to ensure it. “A comprehensive monitoring strategy ensures that costs are minimized and is an important part of the overall context of maintaining quality throughout the distribution system,” he said.