Utilizing Unique Data from File-based Media for Program Detection and CALM Compliance

摘要

In the United States, the inception of the CommercialAdvertisement Loudness Mitigation Act, aka theCALM Act6, has created some confusion anduncertainty within broadcast organizations regardingboth infrastructure (tools, workflow, logging, etc.) andcompliance. While the Federal CommunicationsCommission (FCC) has defined compliance inrelatively concrete terms in FCC Report and Order(R&O) 11-182, “Implementation of the CommercialAdvertisement Loudness Mitigation (CALM) Act8”,how to achieve compliance relative to the FCC’simplementation directives remains unclear. For manybroadcasters and operators, CALM compliance remainssomewhat of a mystery and involves a significantamount of manual effort and expense.While the proper provisioning of broadcast receptionand delivery equipment is a component of provingCALM compliance and receiving “certification” asdefined by the FCC in R&O document 11-1826, themost certain method of ensuring compliance andfulfilling reporting requirements for “spot checks2” and“periodic testing8” of non-certified programmingremains the measurement and logging of programcontent targeted by the statute. Indeed, R&O 11-182expressly states, “…a station may demonstratecompliance…in response to an enforcementinquiry…by demonstrating actual compliance…8”(emphasis added). However, accurate and reliablemeasurement of commercial content within a broadcastsignal has been an elusive goal, and is currentlyachieved through long-term archiving of content andmanual sifting of data to match short-term loudnessmeasurements that exceed target boundaries to theprogramming responsible in an effort to matchcommercial programming (aka secondaryprogramming) to the measurement, as opposed to themain program they accompany8 (aka primaryprogramming). An alternative method has been tocompress audio content for all broadcast programming,primary and secondary, thereby removing dynamicsand in essence reverting to the legacy and somewhatantiquated analog television system of audio processingthereby eliminating erasing one of the chief promisesand advantages of digital television.This paper proposes a new method of achieving CALMcompliance through a novel approach to programdetection using existing file-based media processingtools and widely accepted “cloud-based” networksystems and a new, out-of-band, data analysis system tocreate a fully automated method of programmeasurement, logging and CALM compliance reporting.Accurate identification of programming subject to theCALM Act additionally allows high valueprogramming like movies and scripted shows to beconveyed with cinematic audio attributes like highdynamic range and not be inadvertently or purposefullyprocessed unnecessarily to achieve complianceaccording to CALM statute requirements.