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In depth: The French take on loudness

After nearly 30 years of ineffectual laws and persistent complaints from viewers, France has got tough on loudness with a "global" loudness alignment system and severe penalties. Kevin Hilton looks at the new regulations and how France Télévisions has approached them.

Loudness is an international broadcasting problem. It’s not just that every country in the world with TV services has to address the issue of level discrepancies between different types of programme material, there is a global connection because of the lucrative import-export trade in programmes.Since 2006, when the ITU established BS 1770 as a common algorithm and recommendation for loudness control, national governments and broadcast regulators have been implementing or considering formal regulation to reduce the number of complaints from viewers about this bane of modern life.In Italy the Authority for Communications (AGCOM) brought in rules based on 1770 during 2006 that cover all broadcast material, with a maximum difference between them of 0.6dB. The UK’s Broadcast Committee on Advertising Practice (BCAP) introduced guidelines in 2008 but for commercials only.The industry saw 1770 as a start but many experts thought more could be done. The EBU’s PLOUD working group began working on improvements and published R128 in August 2010. This was based on 1770 but new features, including gating, were added for greater control. The ITU issued a version two of 1770 last year that incorporated the gate.In the US the ATSC (Advanced Television Systems Committee) formulated A/85, again based on 1770, which is the technical basis of the CALM (Commercial Advertisement Loudness Mitigation) Act. This comes into full effect on 13 December when the FCC (Federal Communications Commission) will be able to fine any company breaking the rules.After attempting to enforce loudness control in a similar legal fashion over the years, France now has a single loudness alignment system, which came into force from 19 December 2011. The regulations are compatible with R128 and work to the target of -23 LUFS. It was agreed by all national broadcasters, including public service France Télévisions, advertisers and the CSA (Audiovisual Superior Council).This consensus was been reached after viewer complaints and two previous laws over the last 26 years, none of which had any substantial effect on the problem of loudness. The first law was passed in 1986, followed by a second in 1992. France adopted 1770 in 2008 and added Dolby Dialogue Intelligence to it. A listening reference level was also set but, explained Matthieu Parmentier (pictured speaking at the London Loudness Summit during December), innovations and developments manager for France Télévisions, by the end of that year broadcasters felt the standard was limited, with approximately 20% of programmes sounding outside the set range.The French broadcast sector joined PLOUD and from 2010 onwards began moving towards a new set of guidelines, with loudness tools based on R128. Seminars were held to promote the standard, leading to broadcasters and advertisers agreeing a single recommendation on how to deal with loudness in 2011.Under the new law all broadcast material – including commercials, domestic programmes and bought-in English-language material – has to adhere to strict guidelines: programmes under two minutes cannot exceed -23 LUFS (integrated) and -20 LUFS in the short term; programmes longer than two minutes must have an integrated loudness of -23 LUFS +/-1 and have a loudness range between 5 and 20 LU; dialogue has to be set between -30 and -16 LUFS in the short term.These regulations apply to distribution companies as well as broadcasters; anyone breaking them faces penalties of up to 2% of revenue. Parmentier explained that a new French standard for loudness was important because a number of factors were coming together; free-to-air HD services were being introduced, analogue TV was due to be switched off and multi-channel sound broadcasting was expanding, all at a time when there was no listening level reference for TV mixing.Parmentier added that another consideration was for the French post-production market, which he said was very strong, to secure its business. Although Parmentier observed that “there was still some work to do”, with a “progressive calendar” of targets and implementation running up to 2016, there can be no doubt that, despite the false starts, France is addressing loudness