Sonoma County, Calif.
Gallo's proposed Russian River Valley AVA expansion is outlined in dotted red.
PHOTO: RRVW and Appellation America
-- A request by Gallo
Family Vineyards to expand the Russian River Valley American Viticultural Area (AVA) by an additional 14,044 acres is drawing heated opposition from growers and wineries both within and outside of the current boundaries.
At 169,028 acres, the Russian River Valley (RRV) appellation is already vast; the proposed expansion would increase its acreage by about 9%, according to the federal Tax and Trade Bureau (TTB) Notice No. 90
. Gallo requested the change in order to have its 350-acre Two Rock Ranch Vineyard included within the RRV AVA, which is internationally known for producing Chardonnay, Pinot Noir and other winegrape varieties of high quality.
The TTB published the proposed change on Aug. 20, when it called for public comments prior to Oct. 20. So far, several dozen comments are posted on the site, including a petition from an ad hoc organization calling itself the Russian River Boundary Integrity Coalition (BIC). Spearheaded by winemaker Merry Edwards
, who oversaw the RRV's most recent boundary alteration in 2005, BIC's position is adamantly anti-expansion. (The petition and all other public comments are posted at the website above.)
Edwards, whose self-named winery in Sebastopol produces about 17,000 cases of prized Pinot Noir and Sauvignon Blanc annually, told Wines & Vines
that she felt the initial deadline, smack in the middle of Sonoma's crush, provided inadequate time for expansion opponents to marshal their arguments. She sought, and received, an extension, and the TTB will now accept public comments pro and con until Dec. 20.
Edwards herself submitted comments and background material against the proposal on Sept. 11. "My major concerns are the potential devaluation of the vineyard properties my company owns in Russian River Valley, the reduction in the integrity and value of our regional Russian River Valley brand, and the consumer confusion which is sure to occur if this petition passes," she wrote. She cited her personal experience from the Petaluma Gap area of the Sonoma Coast AVA, which she considers the Gallo property's rightful designation.
"The grapes and the resulting wine from that area bear no resemblance to wines grown in the RRV…. Not withstanding good maturity, they show under-ripe, green qualities and substantially lower body and color, inconsistent with our wines from the RRV AVA," she stated.
Edwards also submitted an anti-expansion petition from BIC, bearing some 92 signatures. The TTB's extension of the comment period, she said on Friday, is allowing the coalition to organize more opposition. "We're just getting the word out," she said. "I've been feeling isolated, but people say they want something to happen." To that end, she has written and is now circulating a letter among the community, headlined, "Russian River Valley Is Your AVA--Make Your Voices Heard!"
She explained that the current boundaries for the Russian River Valley AVA were 10 years in the making, the result of a community effort that involved Gina Gallo, then a board member of the Russian River Valley Winegrowers
. (The group has remained neutral during the current debate.)
She expressed concern also for members of the Petaluma Gap Winegrowers Alliance
, a group founded two years ago to foster recognition and, she said, build a foundation for its own AVA. "The Petaluma gap is the rightful appellation of these small, family-owned farms, although it's not yet recognized by the government," Edwards said.
Instead of expanding the RRV, Edwards said she had advised Gallo representatives to "build the Petaluma gap." She complained that "TTB is cooperating with a single company," and expressed fears that the community as a whole may be overlooked. In a postscript to her comment to the TTB, she quoted the agency's own ruling, published in the Federal Register, Volume 73 #162 on Aug. 20: "Any benefit derived from the use of a viticultural area name would be the result of a proprietor's efforts and consumer acceptance of wines from that area."
It seems, she continued, that, "In the case of expansions to any existing AVA, the petitioner will benefit from the efforts of those winegrowers who founded and promoted the AVA. Likewise, any degradation of quality or regional character caused by an expansion could have 'a significant economic impact on a substantial number of small entities.'"
Art Resnick, who handles public and media affairs for the TTB, emphasized, however, "We take great pride in working with industry members to reach solutions that meet the requirements of law and regulation and help commerce. We like to be as transparent as we can, working in partnership with the regulated industry to achieve voluntary compliance, and not to put anyone out of business."
Some, like winemaker Merry Edwards, would like Gallo's Two Rock property to become part of a future Petaluma Gap sub-appellation, as outlined here.
PHOTO: The Map Store
Asked how the TTB weighs the public comments it receives, he explained that it is not the number of comments, but their substance both for and against a requested rulemaking that make a difference. "It depends what we see in the comments, how valid they are. There could be two or three, or a couple of hundred. It depends on the meat of the comments; if something is said that would send us back to the drawing board. Some (proposals) are cut and dry; on some we scratch our heads."
One of the more substantive comments posted to date came from Maurice "Joe" Nugent, who grows 11 acres of Pinot Noir within the current Russian River Valley. He sells these to Robert Stemmler Winery for a vineyard-designated wine. Nugent has been a grower for almost a dozen years and holds a Ph.D. in chemistry.
"The growing season for the Gallo expansion area," he wrote, "appears to be much longer…than it is in the Russian River Valley. In fact, Gallo had not picked their red varietal (presumably Pinot Noir) by Oct. 4, 2008….Most Pinot Noir and Chardonnay in the Russian River Valley was picked by the weekend of Sept. 14," more than three weeks earlier, he said.
Nugent's comments go on to include specific arguments against Gallo's submission. He refutes Gallo's claim that the proposed expansion area is within the Russia River watershed; that it was historically considered part of the RRV and that its growing patterns are similar.
"The Russian River Valley, which has become one of the most important grapegrowing regions in the world, is extremely important to the economy of Sonoma County and the consumers who purchase our wines." He recommended that Gallo open its facilities for outside verification of harvest dates, a delay, he wrote, that "Will certainly not harm Gallo," while "An unjustified, hasty expansion would harm an agricultural treasure and violate the TTB's mission to protect consumers."
Jim Collins, senior director of winegrowing for E. & J. Gallo, said he believes there is "pretty broad support for the expansion." He told Wines & Vines, "Facts are facts. We are resting our petition on the scientific data." He said that the BIC petition contained "hard to verify" or duplicate signatures.
Moreover, he said, Gallo had bowed to community pressure during the 2005 petition that drew the AVA's current boundaries. "We had planned on asking for the expansion then, but were approached by folks within the RRV AVA, who described economic hardships if the process went on longer. We didn't want to put anyone in economic harm. I think the facts bear out what we are trying too do." Collins expressed confidence that the TTB will eventually rule in favor of the proposed expansion.
Which side are you on? The election may be over but you can still cast a vote on this issue. Stakeholders, industry observers and consumers are all encouraged to visit the TTB website, read Gallo's proposal, and share your comments, "yay" or "nay." You've got until Dec. 20.