I agree with the ADC side, but is there any reason why in mastering the CD track that the volumes wouldn't be normalised, or close to it? I can't imagine any digital album available as a commercial product would have a maximum peak 20dB down, these days a lot of albums spend most of their time at 0 to -3dB down!
Actually, that reminds of a question I was going to bring up at some time, regarding levels fed to the ADC while recording, perhaps you or Bruce or someone can answer this: is there any inherent reason, or perhaps it's already done in some equipment, why the analogue feed to the converter can't be split to go to, say, 2 converters, with a level difference of say, 20dB difference between the two? The reason for this, one converter gets a much higher signal level, it's working in the sweet spot of its range, but now and again it will clip, deliberately so, but the other converter has 20dB headroom and picks the signal up cleanly during this clipping period -- both converters record the session to 2 separate sets of tracks. Then, after the session, the clipped areas of the higher quality recording are repaired by the "safety" recording, trivially easy to do for software, and instantly you have 20dB better dynamic range for recording.
Thanks,
Frank