Hey Adam, I agree with you on most points and certainly understand the limitation of the article, I guess that's the art of writing succinctly.
In regards to the loudness of adverts, unless the advertisement is determined (by some known entity) to be
a) excessively noisy or strident
b) or found to be exploiting the sensitivities of human hearing to again be excessively noisy or strident
then it's perfectly acceptable.
I wrote my master's thesis on perceived loudness of broadcast material in which I spent a good amount of time researching loudness in television ads. In regards to complaints, they refer to the legislation detailed below.
"Many countries have introduced legislation to try to control the broadcast loudness problem. The Australian Broadcasting Authority begun an investigation into loud advertisements following a private members' bill dubbed The Quieter Advertising Happier Homes Bill. ‘The authority has ordered commercial television broadcasters to come up with a code’ ‘to be included in the Commercial Television Industry Code of Practice’ that would ‘provide that broadcasters must do everything reasonably possible to ensure that advertisements do not sound louder than adjacent programming’ (Banham 2002, p. 1). The authority also directed the then governing body the Federation of Australian Commercial Television Stations (FACTS) to provide ‘clear limits’ on the use of common techniques used to increase perceived loudness including compression, limiting and equalisation. FACTS was later replaced by Commercial Television Australia (Free TV).
In January 2007, Free TV Australia released an Operational Practice [OP] document, OP-48, to the media which was centred on ‘Audio Levels and Loudness’. It set out the requirements for television advertisements (commercials) in relation to audio levels and loudness’ (‘FreeTV Australia Operational Practice OP-48’ 2007, p. 1). It applies to all television commercials, regardless of delivery format covering both digital and analogue. It requires that producers of commercials comply with the OP ‘as a condition of acceptance for broadcast’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 1). In considering loudness, the OP highlights the ‘correct alignment of audio levels’ and the ‘careful management of dynamic range and spectral content’ as ‘key factors in preventing extreme variations in loudness’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 1).
In addressing alignment levels, the OP states that ‘commercials must be preceded by a one kilohertz tone having a constant relationship to and representing the normal level of the audio material the follows it’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 1). In analogue systems this tone will equate to 0dBVU, in digital systems -20dBFS.
The OP does not discourage the use of compression, rather it states that it ‘should be used appropriately throughout the production process to constrain the dynamic range of vocal and music tracks to produce a controlled and consistent sound track [emphasis added]’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 2). However, the ‘
aggressive use of compression’ (that is commonly used to increase the apparent loudness of advertisements), ‘
must not be used for the purposes of producing excessively noisy or strident material’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 2). Audio limiting (commonly referred to simply as ‘limiting’) is also not discouraged and is highlighted in the OP as a ‘useful tool that can prevent distortion’ and in a similar fashion to compression ‘must not be used for the purposes of producing excessively noisy or strident material’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 2).
As detailed earlier, the human hearing system does not perceive all frequencies with equal amplitude. The auditory canal alone provides a boost of over 10dB to frequencies centred on 4.5kHz (Everest 2001, p. 45). The OP addresses this phenomenon by stating that the ‘a
lteration of the spectral response of the audio system [through the application of equalisation]
to emphasize those frequencies to which the ear is most sensitive, must not be used for the purposes of producing excessively noisy or strident material’ (‘Free TV Australia Operational Practice OP-48’ 2007, p. 2).
Riedmiller et al. (2003) found that an increase in subjective loudness of ‘two to three decibels’ above the previously determined comfortable reference level is enough to move a programme out of a listener’s Comfort Zone, and perhaps into the ‘excessively noisy’ area. Moreover, listeners are extremely sensitive to changes in dialogue levels, agreeing ‘...with each other to within 1dB’ (Riedmiller et al. 2003, p. 6). Thus quantifying what constitutes as ‘excessively noisy’ and ‘strident’ may prove difficult and will certainly yield disagreement amongst viewers when dealing with sounds such as footsteps (Riedmiller et al. 2003, p. 6)."
(Bassett, 2010).
The subsequent AES paper can be found here:
https://secure.aes.org/forum/pubs/conve ... elib=15340