
Live sports production increases complexity, with dynamic audio levels and an overall philosophy that encourages transient volume spikes
Fourteen years ago, American television viewers finally had their voices heard - literally - over the din of gratingly loud broadcast commercials. A longstanding consumer kvetch had been how commercials not only seemed but were shown to be measurably louder than the programs they punctuated. The Commercial Advertisement Loudness Mitigation (CALM) Act, signed into law in 2010 and effective December 2012, required TV commercials to have the same average volume as the programs.
But then came streaming, which brought with it an entirely new frontier of inconsistent sound. That's complicated by the much more crowded commercial-streaming landscape, now populated by massive media brands - Netflix, Hulu, Disney+, Amazon Prime Video, Apple+ - many of which have begun carrying major-league sports, and commercials.
Telos Alliance's Costa Nikols: Early [streaming] platforms treated audio as an afterthought. [With] streaming now the primary delivery path for many viewers, problems that were niche or background are now everybody's main pain point. It has always been an issue, but I think the scale and visibility of the problem has changed dramatically over the last few years [with streaming], observes Costa Nikols, exec-team strategy advisor, M&E, Telos Alliance, which makes a range of monitoring and measurement devices and systems addressing the loudness problem for both broadcast and now streaming. Inconsistent volume has been part of streaming since the earliest days of online media, but, unlike broadcast, streaming never had a single enforced loudness regime. Early platforms were small, fragmented, and treated audio as an afterthought. What has changed radically is that now streaming is the primary delivery path for many viewers. Problems that were once niche or background are now everybody's main pain point.
A Decade of Fixes
Just as streaming's infrastructure came together in fits and starts, so have solutions to its volume problems. The CALM Act uses ATSC A/85 standards to limit jarring jumps in volume, with the FCC appointed to enforce the rules requiring TV stations and cable operators to adhere to specific audio-level standards.
Last October, California enacted SB 576, extending the federal CALM Act to streaming services, which had previously not been subject to commercial volume regulations passed by Congress in 2010, said California Gov. Gavin Newsom when he signed it last year. After the law takes effect in July, the bill states, a video-streaming service that serves consumers residing in the state shall not transmit the audio of commercial advertisements louder than the video content the advertisements accompany, consistent with the regulations adopted by the Federal Communications Commission pursuant to the [CALM Act] for television broadcast stations, cable operators, and other multichannel video programming distributors.
The CALM Act helped but did not eliminate the problem. Various audio-compression systems were able to, intentionally or not, elide or outright avoid the guidelines. But it was still an improvement over the noisy world before.
The guidelines have undergone periodic revisions, including ways of measuring comparative broadcast levels and refinements to dialog normalization (Dialnorm). The Dolby-developed metadata parameter in the Dolby Digital AC-3/AC-4 set of standards tells audio decoders how loud dialog is, allowing the decoders to adjust playback gain to keep volume consistent across different content and channels. It typically ranges from -1 to -31 dB, reducing output to a -31 dB standard. The monster was, if not tamed, then at least managed.
States Take the Streaming Lead
The federal CALM Act relies on consumer complaints to identify patterns of abuse, and, although violations can lead to fines, enforcement thus far has not extended beyond warnings. As of early 2025, no public enforcement actions or financial penalties had been reported by the FCC against a television station for violations, despite the agency's having received thousands of complaints annually since the rules were adopted in 2012. However, the subjective nature of noise complaints likely contributes to the lack of prosecution of alleged violations.
On the other hand, in California, fines of up to $2,500 per violation can be imposed on streaming services once SB 576 becomes effective this summer. With many streamers based in the state - notably, Apple, Netflix, and Amazon Prime - California's enforcement approach is widely expected to set the pattern for other states that choose to pursue the matter.
Possibly prompted by California's action, the FCC announced this month that it is seeking comments on whether to issue a notice of proposed rulemaking (NPRM) that would put the idea of new rules and enforcement abilities back on the legislative table.
Multiple Sources Complicate Noise Control
Any efforts to regulate loudness control with streaming will have a complex technical terrain to contend with, Nikols notes. That includes ads arriving at different loudness levels from various sources using different encoding pipelines across ad vendors, device playback differences (TVs, phones, etc.), and older legacy content that doesn't meet modern loudness standards and may need reprocessing.
On the supply side, a single service might carry movies, live sports, user-generated content, promos, and ads, each produced under different loudness assumptions. Furthermore, the ad-tech servers delivering these ads are not necessarily normalized in terms of their own internal specifications. For instance, an ad might be at -24 LKFS (loudness, K-weighted, a standard unit for measuring audio loudness; a value typically used as a t
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