Posted 07 January 2011 - 08:17 PM
If you can show audio peaks on the commercials set more bits than does the program material, you can cite the media provider as not being in compliance with the law. This is straightforwardly measurable.
But, there are well known techniques that compress the peaks allowing the average power in the modulating signal envelope to increase. So it's possible to make the commercial audio sound louder even if the audio peaks don't set as many bits.
That's more the essence of perceived loudness.
The FCC handles the complex technical details of a simply worded law. So, somehow, they must determine exactly what loudness is and establish a technical standard for measuring it though its rule making process.
But I don't want to go among mad people