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TTB proposal

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TTB Notice to Open Comments on the Proposed Expansion of the Sta Rita Hills AVA

It was announced today (August 6, 2014) that the TTB will open comments tomorrow in approving a petition to expand the Sta Rita Hills AVA. The comment period will open for exactly two months allowing interested parties to submit information and perspective on the matter until October 6, 2014. Information on how to submit comment, as well as the full press release from the TTB are copied below.

The proposed expansion of the Sta Rita Hills AVA has proved a hugely controversial topic. The Sta Rita Hills Winegrowers Alliance has publicly declared its opposition to the proposed expansion. Alliance members include producers growing and/or sourcing fruit from throughout the appellation, as well as many of the individuals that worked on and submitted the original AVA proposal for the Sta Rita Hills.

The petition for expansion of the AVA was submitted March 2013 by Patrick Shabram on behalf of both John Sebastiano Vineyards, and Pence Ranch Vineyards. Shabram works as an academic geographer with a background in the study of viticultural areas. Notably, he helped define and submit the successful AVA proposals for Fort Ross-Seaview and Moon Mountain AVAs in Sonoma County.

In the discussion back and forth around the issue, Pence Ranch Vineyards has received the most direct criticism for the proposed expansion. However, John Sebastiano Vineyards would also be directly affected if the boundary change is approved as the vineyard currently is bifurcated by the Northeast appellation boundary. Visiting the site one can stand at the top of the hill and literally jump in and out of the Sta Rita Hills while still surrounded on all sides by Pinot Noir. The economic value of clusters from just inside the boundary far outpace those from those just outside of it (even with them growing mere feet apart) thanks to the high dollar value placed on Sta Rita Hills fruit.

Defining the Sta Rita Hills

Wes Hagen stands as the most vocal proponent of preserving the current definition of the American Viticulture Area (AVA), Sta Rita Hills. Hagen helped successfully define and submit the original proposal.

In considering the value of the appellation itself, Hagen names topography as the definitive element of Sta Rita Hills growing conditions. The Sta Rita Hills are defined by a unique East-West transverse mountain range that sits open-mouthed to the Pacific Ocean, effectively funneling maritime elements inland. It is this topography that generates unique temperature, wind, and fog throughout the growing region.

Hagen describes the shape of the Sta Rita Hills as essentially closely spaced hills that concentrate ocean influence. What is important in this account is the manner in which the landscape of the region intensifies the cooling–both in terms of temperature and air flow–and humidity of the growing region when compared to areas through the rest of the Santa Ynez Valley. As you drive over the crest of the hill on Highway 246 that delineates the Northeastern boundary of the AVA, the topography changes from the closely spaced hillside-to-valley proportion that holds in the ocean influence, to the much more open valley formation of the greater Santa Ynez Valley. For Hagen, this geographical change illustrates the features central to the growing style of the Sta Rita Hills versus the Santa Ynez Valley more broadly.

Studying the Expansion

Together John Sebastiano Vineyards and Pence Ranch Vineyards hired geographical consultant, Patrick Shabram to do a thorough going study of the Sta Rita Hills and the area just outside its Northeastern boundary, as well as portions of the Santa Ynez Valley more broadly. The purpose of the study was to determine whether or not it was reasonable to consider a possible expansion to the AVA.

Shabram drew on data from weather stations throughout the appellation in comparison to similar data from further east in the Valley, soil analysis from within the AVA and to the East of it, and on vegetation patterns (both vines and otherwise) from throughout the region as well in order to determine the best recommendation for articulating a coherent appellation boundary. An important difference from Shabram’s study versus the definition of the original AVA proposal rests simply in access to an increase in information today.

Since the original Sta Rita Hills appellation approval in 2001, there has been a significantly large increase in vineyard plantings through the region. One of the affects of such a change includes the increase in weather stations collecting climate data throughout the region. The volume of information available today about the area, then, proves to be significantly greater. According to Shabram, access to such data legitimates the currently proposed expansion of the AVA.

Climate Considerations

Sta Rita Hills Vineyard Map

Sta Rita Hills Vineyard Map found: http://www.staritahills.com/appellation/

Temperature changes and wind patterns prove central to both sides of the Sta Rita Hills debate. Hagen points out that the Northeastern boundary delineates a climate change for the Santa Ynez Valley. In Hagen’s view, overall temperatures increase past the crest of the hill on Highway 246, and wind patterns dissipate lessening the concentration of maritime influence through the rest of the Valley. It is not that fog or wind disappears beyond the crest of the hill–spend any significant time in the region and it quickly becomes clear that a daily pattern of both stretches all the way to the warmest reaches of Happy Canyon–according to Hagen it is that they become measurably less concentrated. For example, according to Hagen, the temperatures to the West of the Northeastern boundary of the appellation is measurably less than those East of the boundary.

According to Shabram, the relevant temperature features are more subtle than that. The Sta Rita Hills appellation is essentially bifurcated into two unique subzones. On the Southern side, the Santa Rosa-to-Sweeney-Rd portion of the Sta Rita Hills is separated from the Highway 246 corridor on the Northern side by a central hill formation. Shabram points out that those central hills generate two unique wind patterns with one funneling in from the ocean on the Santa Ynez River on the Santa Rosa-to-Sweeney Rd portion, and the other funneling in over the Highway 246 corridor.

Within the existing appellation, Rio Vista Vineyards sits at the central-Eastern boundary of the appellation along the Santa Ynez River. According to temperature data studied by Shabram, temperatures just prior to Rio Vista Vineyards, within the current appellation boundaries, are actually noticeably warmer than those within the proposed expansion area.

Looking at the wind patterns through the region explains the temperature comparison. According to Shabram, Hagen is right that ocean winds dissipate towards the Eastern side of Sta Rita Hills. The warm zone prior to Rio Vista Vineyards reflects this reduced wind pattern. However, according to Shabram, right around Rio Vista Vineyards, the Santa Ynez wind pattern combines with the Highway corridor wind pattern effectively increasing the overall wind effect, and decreasing overall temperatures. The result is that within the proposed expansion area temperatures are lower, and wind is higher than the zone to the southeast within the current appellation boundary.

To the extent that the question of a proposed expansion rests in temperature and wind patterns, then, the area within the proposed expansion area, outside the current Northeastern boundary, would seem to be consistent with the current appellation conditions. However, the appellation expansion is not dependent only on wind or temperature. As Hagen explains, the appellation is more centrally about overall topography. Topography directly impacts temperature and wind patterns but does not reduce to these elements.

Questions of Soil Consistency and the Now Proposed Eastern Boundary

Soil series types within the Sta Rita Hills are notoriously varied. Extensive discussion of the value of the mixed loams, Diatomaceous Earth, and shale on the Santa Rosa-to-Sweeney Rd side, versus the more consistently sandy loam of the Highway side has occurred. The well known soil differences through the Sta Rita Hills illustrate the peripheral nature of soil in defining what is key to the Sta Rita Hills appellation. Both Hagen and Shabram agree that soil is not central to the definition of the appellation.

The area within the proposed expansion of the boundary carries soil series types consistent with those directly West within the current appellation. In doing the regional study, Shabram did analysis of the series types throughout Sta Rita Hills, in the proposed expansion, and within the areas East within Santa Ynez Valley more broadly. What he found was that the six soil types within the proposed expansion area show as generally consistent with those to the West within the appellation. Moving East into lower elevations towards Buellton, however, the soil series types begin to change with proportions of some types greatly reducing compared to within the appellation, and the appearance of others that do not appear at all with the Hills.

Shabram emphasizes that soil types analysis does not play a central role in the new expansion proposal, but the analysis is included in the proposal. One reason for including the analysis is that the change in soil types assisted in delineating the Eastern boundary of the proposed expansion. Shabram suggested the expanded boundary in relation to higher elevation areas that include consistent soil series types.

The Value of a Name

Central to the question of expanding the Sta Rita Hills AVA stands the concern for integrity of the name Sta Rita Hills. Such issue is not trivial convention. Behind the project of the American Viticultural Area branding program is the articulation of a signature quality of grape growing uniquely generated by the overall conditions of the named region. What characteristics prove most central to that signature depends on the dictates of the region itself. The list of elements relevant for consideration, however, remains generally consistent and include historical precedent and practice, climatic conditions (including wind, fog, light, temperature, etc), topographical formation, and soil type.

According to the Sta Rita Hills original proposal, topography as it operates to concentrate the maritime influence on the growing conditions of the region centrally defines that region. In suggesting an expansion of the Eastern boundary along the Highway 246 corridor, the new proposal focuses in on the details within the topography bringing questions of temperature, wind, and fog, that is overall climate, to the fore.

Members of the Sta Rita Hills Winegrowing Alliance are adamant that the expansion should not occur. Their arguments against the expansion rest largely in the continued integrity of the appellation itself. The question of integrity here assumes the original articulation of the growing region is the more clear, appropriate definition of what makes Sta Rita Hills fruit unique.

Hagen points out that his fight against the proposed expansion is in no way a matter of whether or not an estate like Pence Ranch Vineyards is growing quality fruit. Instead, it is a matter of whether or not it is growing fruit consistent with that of the Sta Rita Hills. His view is that it is not. For Hagen, the topographical change does not reduce to whether or not wind and fog conditions show within the proposed expansion area. He expects that they do. Instead, it is a matter of their concentration in relation to the overall topographical layout of the Sta Rita Hills. For Hagen, the question of topography stands at the top of a defense for the maintenance of the original appellation. Historical precedent, and the concentration of plantings through the region also support his view.

Shabram, on the other hand, believes the proposed expansion offers a more coherent account of what is uniquely the Sta Rita Hills. In his view, by capturing the climate details, and, peripherally, recognizing the soil consistency, a more thorough going understanding of the signature growing conditions for the region has been made. Shabram points out the intuitive strength of the original proposal. In his view, at a time when thorough going climate data was not available, the original AVA writers did a brilliant job of defining the growing region. For Shabram, the new expansion simply fine tunes that.

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The TTB’s press release announcing movement forward on the proposed expansion follows. The expansion has not currently been approved. However, the TTB has taken a step closer towards finalizing this process. The key point is that the comment period on the matter is now open and will remain open until October 6, 2014.

The comment period allows interested parties the opportunity to weigh in on offering historical information, interpretive data, personal opinion, and social consensus that the reviewing committee might not otherwise be aware of, and can have a great impact on how the process moves forward.

Information on how to comment follows at the bottom of the original press release.

Updates on this issue including comments from other relevant parties will appear here.

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TTB PRESS RELEASE:

Proposed Expansion of the Sta. Rita Hills Viticultural Area

Washington, D.C. — The Alcohol and Tobacco Tax and Trade Bureau will publish a notice of proposed rulemaking in the Federal Register on Thursday, August 7, 2014, proposing to expand the existing 33,380-acre “Sta. Rita Hills” American viticultural area in Santa Barbara County, California, by approximately 2,296 acres. The existing Sta. Rita Hills viticultural area and the proposed expansion are located entirely within the established Santa Ynez Valley and Central Coast viticultural areas. TTB is making this proposal in response to a petition filed on behalf of several local wine industry members. TTB designates viticultural areas to allow vintners to better describe the origin of their wines and to allow consumers to better identify wines they may purchase.

You may submit comments on this proposal and view copies of the proposed rule, selected supporting materials, and any comments TTB receives about this proposal at the “Regulations.gov” website (http://www.regulations.gov) within Docket No. TTB– 2014–0007. A link to that docket is posted on the TTB website at http://www.ttb.gov/wine/wine-rulemaking.shtml under Notice No. 145.

Alternatively, written comments may be submitted to one of these addresses:

•    U.S. Mail: Director, Regulations and Rulings Division, Alcohol and Tobacco Tax and Trade Bureau, 1310 G Street NW., Box 12, Washington, DC 20005; or

•    Hand delivery/courier in lieu of mail: Alcohol and Tobacco Tax and Trade Bureau, 1310 G Street, NW., Suite 200–E, Washington, DC 20005.

Comments on this proposal must be received on or before October 6, 2014.

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