commercials are allowed to be AS loud as the loudest part of the program they preceed. So, if you are watching a shoot out, blow up explosion kinda thing, you will find that the commercials are as loud as those explosions! The advertisers were complaining that with Tivo, DVR and so on, people were skipping their ads, or getting up to do other things while commercials were on, and since they paid to place the ads there, they wanted a way to "be heard"

I hope we all switch to IN program advertising. you know, see them drinking maxwell house, or country time lemonade instead of being pelted with battery commericals on the break. Just show the energizer brand name when the child is inserting them into his toys. The subliminal factor alone would be more tempting than screaming at us during the break.