LOUDNESS STATUS IN BRAZILLuiz Fausto

Rede Globo

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

AGENDA Law # 10 222 (2001) Judicial Decision (February/2012) Ministry of Communications - Regulation # 354 (July/2012) Why theres a Loudness Range limit? Why not to use loudness metadata in Brazil? Comparing Loudness Rules: Brazil x U.S. Loudness Control Compliance Monitoring Calculating the chances of infraction Questions?

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

Presidency of the RepublicOffice of the Chief of Staff

Cabinet Subcommittee for Legal Affairs

Law No. 10 222, of May 9th, 2001.Standardizes the volume of audio of radio and television broadcasts

in the spaces dedicated to advertising and takes other measures.

THE PRESIDENT OF THE REPUBLIC: I make known that the Congress decrees and I sanction the following Law:

Article 1 - The audio and audiovisual broadcasting services must standardize their audio signals, so that, on reception, there should be no unjustifiable increase in the volume on commercial breaks.

Article 2 - The Executive Branch will create, within one hundred twenty days from the date of publication of this Law, the required mechanisms for the technical standardization and compliance monitoring.

Article 3 - The breach of the provisions of this Law shall subject the offender to suspension of activity for a period of thirty days, tripled for repeat offenders.

scope: free, over-the-air radio & television (analog and digital)

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

JUDICIAL DECISION (FEBRUARY/2012)

In February/2012, the Brazilian Ministry of Communications was forced by a judicial decision to prescribe a regulation pursuant to the Law # 10 222 (2001) until July/2013

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

MINISTRY OF COMMUNICATIONSREGULATION # 354 (JULY/2012)

Loudness Measurement of each block according to EBU R 128-2011 Fixed Loudness: -23 LUFS (2 LU) Loudness Range Limit: 15 LU Regulatory Agency active compliance monitoring (not consumer-complaint-driven): 6 samples (program block + successive advertisement block) within 48 hours (no sampling criteria established, the 6

worst samples could be selected) Infraction of Law # 10 222 if the advertisement block is more than 2 LU louder than the program block

in more than one sample (this would require adjusting the blocks with 1 LU tolerance) 1st infraction: warning (the next sanction is the suspension, according to the Law # 10 222) Program blocks shorter than 10 minutes and advertisement blocks shorter than 2 1/2 minutes

should be disregarded (to allow real-time loudness processors to converge to the desired average) Whenever possible programs with live externally captured audio should be disregarded (you cant

count on that) Starts July 11th, 2013

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

WHY THERES A LOUDNESS RANGE LIMIT?

adjusting only the average wont ensure comfortable transitions

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

WHY NOT TO USELOUDNESS METADATA IN BRAZIL?

Metadata doesnt apply for analog broadcast

Brazilian Terrestrial Digital Television system uses MPEG-4 AAC audio

Although MPEG-4 AAC has provisions for loudness related metadata (program_ref_level, DRC), its usage is not properly standardized nor properly implemented (neither on encoders nor on decoders)

It wouldnt help much, anyway

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

COMPARING LOUDNESS RULES: BRAZIL X U.S.Brazil U.S.

Measurement Method Each blockusing EBU R 128-2011

Each program/commercialusing ITU-R BS.1770

(with any gate)

Integrated Loudness -23 LUFS(2 LU)metadata correctly set

(2 LU)Loudness Range Limit 15 LU none

Maximum advertisement block integrated loudness increase relative to previous program block 2 LU

not specified(possibly more than 4 LU)

Regulatory Agency compliance monitoringactive

(not consumer-complaint-driven)

reactive(consumer-

complaint-driven)

Sanction suspension ofup to 90 days up to US$ 10,000 fine

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

LOUDNESS CONTROL No real-time loudness processor can ensure compliance (it can help, though) Excessive processing can deteriorate audio quality severely and yet wont ensure

compliance Cascading loudness processors on the signal chain generally leads to undesired results File-Based solutions can ensure compliance of the pre-recorded material with no

impact on audio quality when adjusting integrated loudness and with the minimum possible quality impact when limiting the Loudness Range; nevertheless, the impact on the workflow (latency) must be considered On all audio production environments, but specially when producing live, legacy meters (VU,

PPM) must be replaced by loudness meters (it also requires training) When downmixing or upmixing a signal, the loudness is generally not preserved

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

COMPLIANCE MONITORING

Compliance monitoring requires either an automated trigger on blocks boundaries or manual operation (live or segmenting after recording)

Brazilian rules should be applied when interpreting the results

L o u d n e s s S t a t u s i n B r a z i l - L u i z F a u s t o - R e d e G l o b o

CALCULATING THE CHANCES OF INFRACTION We broadcast, in average, 160 pairs of program and advertisement blocks within 48

hours; as only one of these pairs is allowed to fail, 99.4% of them should be within specified tolerance

The counting of samples that failed to stick within the specified tolerance within 48 hours may be considered a random variable that can be modeled by a Poisson distribution. Each station can be monitored many times in a year. The probability of infraction in at least one of these is then given by:

where is the average failure rate (within 48 hours) and n is the number of times the station is monitored. Supposing =1 and n=1, the probability of infraction would became 26.4%.

QUESTIONS?luiz.fausto@tvglobo.com.br

THE ENDThanks!