Comment 3: Hannum, Natalie

September 17, 2010 To Whom It May Concern: This correspondence is regarding Docket No. TTB-2010-005 ; Notice No. 108, Proposed Establishment of the Antelope Valley of the California High Desert Viticultural Area. In reading the proposal, Section 4.25(e)(2) of the TTB regulations require that “evidence that the proposed viticultural area is locally and/or nationally known by the name specified in the petition,” I would argue that The Antelope Valley of the California High Desert does not meet the requirement for geographic recognition. Having traveled the area, the proposed boundaries and geographic features do not adequately “define” the area. One could traverse the proposed Antelope Valley of the High Desert Viticulture Area and never realize they had ever left or returned. The proposed area is simply too vast and travelers would only know they are on the “high desert”. More importantly, outside of southern California, very few would recognize the high desert or Antelope Valley as areas as recognizable or significant geographic areas for the purpose of wine grapes and the production of wine. Additionally, the TTB Regulations call for “historical or current evidence that supports the boundary…” The petition calls for the designation of 665 square miles in the region to be classified under the viticulture area, but it lacks sufficient evidence of the historical or current context to support the petition. It sites a history of the late 1800’s when the region had 239 acres of vines under cultivation of which 6.5 acres were for wine grapes, and the present day inventory of 128 planted acres. For a 665 square mile proposal, this seems to be negligible evidence of historical or current value. The designation is a significant marketing tool for wine makers. As such, regions applying for the designation should provide adequate evidence that the region can produce wine of a sufficient quality and character that it can be defined by those characteristics. This is the main purpose of the FAA Act, which is to protect consumers against fraudulent claims of quality and to ensure wines come from designated regions. This is a critical concern since California as a state is highly recognizable for fine wines. As such, the introduction of new viticulture areas must be vetted thoroughly so as to protect other areas that righteously meet the criteria of the rules set forth in the FAA Act. In closing, I respect the growers and wine makers of the region for seeking the designation of the Antelope Valley of the California High Desert, but the petitioners fail to meet the two of the four requirements under section 4.25(e)(2) of the TTB regulations. The lack of local or national recognition and the lack of historical or current evidence that supports the boundary setting is a concern. California is synonymous for outstanding wine, and the industry significantly contributes to the California’s economy. Therefore, any viticulture designations must be granted only when all elements of the rules have been satisfied. This petition does not satisfy all elements. Thank you, Natalie Hannum 43960 Alencon Court Temecula, CA 92592