In one of the letters sent Wednesday to Judy Vogel, head of the American Association of Advertising Agencies' media research committee, Nielsen also rebuffed the trade association's request to remove VCR recording data from the new commercial ratings.
In both the letter to OMD's Vogel and one to Ira Sussman, vice president-research at the Cabletelevision Advertising Bureau, Nielsen committed to making improvements in the ad tracking system it uses to identify commercial minutes, that would make it more representative of cable TV networks, and that it would apply to the Media Rating Council to have the system accredited for use as a ratings currency.
That system, Monitor-Plus, originally was not designed to be used as a component of audience ratings, and a number of concerns were raised by the AAAA and the CAB about the way Nielsen plans to use the data to process commercial ratings beginning this fall. Among other things, Monitor-Plus cannot distinguish between national and local commercials for cable networks and does not track commercials for every cable network rated by Nielsen. Nielsen said it is purchasing new "equipment" that would enable Monitor-Plus to distinguish national and local cable commercials and that it should be working by the end of this year. Additionally, Nielsen said it would add eight cable networks not currently tracked by Monitor-Plus and would automatically add any new cable network to the system that it also begins measuring for audience ratings.
In terms of defining what a commercial minute actually is, Nielsen said it is testing two approaches: One that would include all minutes that have 30-seconds or more of national commercial content in them; and a second that would include minutes with any amount of national commercial content in them with the data weighted by the number of commercial seconds within the minute.
"We are currently running an analysis that looks at the differences between the two methods," Nielsen said, adding that it would review its findings with clients before making a final decision on which to use.
However, even with that method in place, it appears that Nielsen will continue to utilize a great deal of value judgment in determining whether certain TV content qualifies as commercial. For one thing, Nielsen said commercial minutes would not include so-called infomercials, or direct response units, but it indicated that defining such units might require some judgment calls. "Monitor-Plus defines a direct response ad as any advertisement that attempts to sell goods directly to the consumer. The simple inclusion of a 1-800 number or a website on the screen does not necessarily qualify as direct response. The advertisement must clearly be prompting an immediate response to act. Phrases such as "here's how to order" or "call now" are typical in a direct response advertisement," Nielsen said.
Nielsen also indicated that it might be difficult to discern commercial minutes with in certain forms of "sponsored" programming, especially ones that claim to be "commercial-free."
"How these sponsorships are handled varies by sponsorship type, and by program provider. As this is therefore a complex topic, we are preparing a separate document to review this subject in detail," Nielsen said.
Network and station promotional spots would not be included as commercial minutes, unless they were purchased as advertising buys on other TV outlets.
In the letter to the AAAA's Vogel, who is also U.S. director of media research and insights at OMD USA, Nielsen revealed it also may have problems processing average minute ratings for national syndicated TV programs. "There are some challenges," Nielsen said alluding to the fact that national syndicated TV shows frequently air multiple runs of the same episode, which are combined into "gross average audience" ratings.
Nielsen said it is analyzing the syndication issue and would likely review the data soon with the Syndicated Network Television Association, individual syndicators and other clients soon.
And in what could emerge as the most controversial issue of all related to the new commercial ratings, Nielsen said it was interested in working with clients to develop new reports that would identify the commercial ratings for "individual creatives across programs." By individual creatives, Nielsen means specific commercials, a development that could lead to direct comparisons on the audience engagement of specific ads and how well they contribute to the total audience of a program or the commercial minute averages.
Finally, Nielsen did not give an explicit timeframe for applying for MRC accreditation, how long he auditing process might take, or when the new commercial ratings would be deemed valid enough to be used as a TV advertising market currency.