Comment from Antelope Valley Winery (Donato, Cyndee)

Document ID: TTB-2007-0068-0003
Document Type: Public Submission
Agency: Alcohol And Tobacco Tax And Trade Bureau
Received Date: November 29 2007, at 12:55 PM 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: 8036a610
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This is comment on Proposed Rule

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

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We are concerned about the following portion of this document: Page 65265 of the Federal Register Vol. 72, No. 223, published Tuesday, November 20, 2007. In the center colomn item #1, requesting comment on "Whether additional or different standards should apply to the establishment of an AVA; for examply, whether there should be a requirement that a specified percentage of the land mass of the proposed AVA be involved in viticultural activities". We believe that it is difficult enough for new viticulture regions to gain recognition / momentum without having to prove that they already have a measurable percentage of a defined geographic area involved in viticultural activities. We futher believe that "percentage of the land mass" does not futher the TTB's AVA program goal 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".