Comment from Wada, Aviva

Document ID: TTB-2008-0009-0009
Document Type: Public Submission
Agency: Alcohol And Tobacco Tax And Trade Bureau
Received Date: September 17 2008, at 06:33 PM Eastern Daylight Time
Date Posted: September 23 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: 
Comment Due Date: December 19 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8070c119
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As a wine consumer, you probably know that the Russian River Valley Area is an AVA designated by the Federal government is the best growing area, perhaps in the world, for Pinot Noir and Chardonnay grapes. The geographical boundaries for this area are decided by the TTB (Department of Treasury Alcohol and Tobacco and Trade Bureau). The geographical integrity of this area is currently being challenged by a single petitioner, Gallo Family Winery of Modesto, who wants their vineyards located South of the Russian River Valley AVA to be included so that they can re-label their wines grown in this area with the Russian River Valley designation. This re-definition of the boundaries could give Gallo an increased market share, which they probably cannot obtain otherwise. In 1994, Ernest Gallo said, “Although at present we are by far the largest winery in the world, we sell only 37% of the wine produced in California. We are not at all happy with this”(Ernest and Julio Gallo “Our Story”, page 337, Random House Inc. NY 1994) According to the TTB, “We designate viticultural areas to allow vintners to better describe the origin of their wines and to allow consumers to better identify wines they may purchase”…” these regulations, among other things, prohibit consumer deception and the use of misleading statements on labels, and ensure that labels provide the consumer with adequate information as to the identity and quality of the product.” (Federal Register / Vol. 73, No. 162 / Wednesday, August 20, 2008 / Proposed Rules) The mission of TTB is in part “to ensure a fair and even marketplace…” (http://www.ttb.gov/about/mission.shtm) Consumers without technical expertise who are opposed to the expansion might ask or expand on: How does the expansion of the Russian River Valley Boundary, based on the desire of a single petitioner to increase his market share help “ensure that labels provide the consumer with adequate information to the identity and quality of the product”? How does the expansion of the boundary on the basis of a petition by single, and already dominant corporation “ensure a fair and even marketplace”?

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