Comment from Howell, Ron C.

Document ID: TTB-2007-0068-0002
Document Type: Public Submission
Agency: Alcohol And Tobacco Tax And Trade Bureau
Received Date: November 28 2007, at 03:31 AM Eastern Standard Time
Date Posted: November 30 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: November 20 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: March 20 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80369384
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This is comment on Proposed Rule

Notice No. 78 -- Proposed Revision of American Viticultural Area Regulations

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Area of concern is on Page 65265 of the Federal Register Vol. 72, No. 223, published Tuesday, November 20, 2007. Item #1: Regarding whether additional or different standards should apply to the establishment of an AVA; for example, whether there should be a requirement that a specified percentage of the land mass of the proposed AVA be involved in viticultural activities. This change would make for an unreasonable hardship in gaining viticultural recognition. It would harm smaller, newer growers and favor established, larger growers. It would seem "percentage of the land mass" is not compatable with the TTB's AVA program objective of "allowing vintners and consumers to attribute a given quality, reputation or other characteristic of a wine made from grapes grown in an area to its geographic origin". Respectfully, Ron Howell