An open letter regarding “TV Volume Fluctuation,” CALM Act


Alan Kraemer, Chief Technology Officer, SRS Labs, has penned an open letter addressing two bills that address the higher volume level inherent in TV commercials. But wait – there’s more! SRS has another solution.

“January 20, 2010

Fellow TV viewers,

Recently, a blow had been struck for the common ear! The CALM act, HR 1084, passed the House on a voice vote and an identical bill has been introduced in the Senate. This is the first attempt by the government to gain control of those blaring commercials that jar you out of your TV watching reverie. In conjunction with the recently adopted ATSC recommended practice A/85, Techniques for Establishing and Maintaining Audio Loudness for Digital Television, this should go a long way to reduce this common annoyance.

Unfortunately, while both efforts were undertaken with the best of intentions, there are still no guarantees of smooth sailing. It turns out the primary target of both the CALM act and ATSC’s A/85 measure is traditional broadcast, one station at a time. Given that, the public will likely be facing at least four major issues that will not be going away:

•Volume level shifts between stations when channel surfing will not be regulated and, therefore, remain uncontrollable. So, switching from channel to channel to find the right program to watch will still prove to be an annoying, frustrating exercise as the volume level will shift up and down even after standards are set in place.

•The insertion of local commercials by cable and satellite providers is another element that is difficult to control. While a commercial might be at an appropriate level for insertion in one network’s feed, it may be way out of line for another. With the hundreds of networks and channels running through a typical cable or satellite plant, this will be extremely difficult to manage, if not impossible.

•Then there are the commercials themselves. These things are designed to get people’s attention, and no advertiser wants his commercial to be perceived as quieter than another or, even worse, quieter than the program. By using clever production techniques, commercial producers can still make their commercials seem loud without exceeding the level of the program material. There are also many cases when the program intentionally tapers off in level for dramatic effect prior to a commercial. Even a well produced advertisement will seem jarring in this situation.

•Finally there is the issue of multiple sources. Much of the TV content people watch today does not originate from conventional broadcasters. Local sources such as game consoles and DVD and Blu-ray players are now being supplemented by streaming content over the internet, all of which have different audio levels and are not subject to regulation.

Fortunately there is a solution; with the processing power available in today’s TVs and Set Top Boxes, it is possible, using advanced DSP algorithms to automatically control volume level at the point of delivery. As long as this can be accomplished unobtrusively, and it can, this approach is the ideal solution. Regardless of the source or level of the incoming content, a volume leveling solution at this point can always make adjustments that are consistent with the user’s needs. This is because the process is fully cognizant of all audio coming into the device. So while HR 6209 and A/85 provide much needed relief, the final nail in the coffin of disturbing volume shifts could ultimately be right in your own living room.


Alan Kraemer

Chief Technology Officer

SRS Labs, Inc.”

RBR-TVBR observation: Yes, SRS makes a solution to this issue, as detailed in this 9/09 WSJ story. But bottom line, if TV commercials are less noticeable because they are at the same volume levels as the programming, they may become less effective. If that happens, advertisers will spend their money elsewhere. Or, perhaps we will see the debut of flashing and moving TV spots like we see on the Internet!  Viewers may long for the days of just loud commercials.  😉