Comment 197

\-\-\-\--Original Message\-\-\-\--\
From: Angela \[mailto:angela@mitchella.com\]\
Sent: Tuesday, April 24, 2007 4:34 PM\
To: Rulemaking, TTB\
Subject: \'TTB Notice No. 71\'

name=Angela Mitchell

name=Mitchella Vineyard & Winery

Address1=2525 Mitchell Ranch Way

Address2=

City=Paso Robles

State=CA

Zip Code=93446

Comments=Mr. Frank Foote, Director

Regulations and Ruling Division

Alcohol, Tobacco, Tax and Trade Bureau

Attention: Notice #71

P.O. Box 14412

Washington, D.C. 20044-4412

RE: Notice No. 71, Proposed Establishment of the Paso Robles Westside

Viticultural Area

Dear Mr. Foote:

I strongly oppose this petition because it does not meet the TTB's

regulatory requirements for the establishment of American Viticultural

Areas; the proposed area extends far beyond what is locally and/or

nationally known by the name Paso Robles Westside and is misleading. In

addition, the area does not possess geographical features such as

climate, soil, elevation, and other physical features that distinguish

it viticulturally from surrounding areas.

The name is used locally to refer to the area west of the city of Paso

Robles, inside and outside of the city limits, but it has never been

applied as broadly as petitioners suggest. The creation of a Paso

Robles Westside AVA suggests that the area of the proposed Paso Robles

Westside AVA is viticulturally distinct from the remaining portions of

the Paso Robles AVA, specifically the implied "Eastside" and this is

grossly inaccurate.

Furthermore, the petition misrepresents the viticultural diversity and

distinctiveness of the "Eastside" of Paso Robles, and makes several

false claims: 1) it (the "Eastside") is as "flat as a billiard table,"

this could not be further from the truth. Our property on the

"Eastside" has evaluations from 610' to 850', far from flat; 2) the

petition also states "the climate is cooler on the Westside of the Paso

Robles AVA." This statement is an overgeneralization and again not

accurate. Our "Eastside" vineyard has lower growing degree day totals

than those at Tablas Creek Vineyard in the middle of the proposed Paso

Robles Westside AVA; 3) the petition also claims "the Westside contains

soils unique to the area." This statement is false. Not a single soil

series mapped as occurring within the proposed Paso Robles Westside AVA

is unique to that area. See comment 129 submitted by Thomas J. Rice,

Ph.D., C.P.S.S.

I encourage you to reject the proposed Paso Robles Westside AVA petition

because it includes several gross inaccuracies that do damage to the

entire Paso Robles AVA but especially the implied "Eastside." In

addition, it will not help build consumer awareness because it is too

broad in scope and misleading; it will only become a source of consumer

confusion. Please review the petitions filed by the Paso Robles AVA

Committee: San Miguel District, Adelaida District, Templeton Gap, Paso

Robles Willow Creek District, Santa Margarita Ranch, Paso Robles

Estrella District, Geneseo District, El Pomar District, Creston

District, Paso Robles Canyon Ranch, and San Juan Creek. I believe you

will find that these proposed petitions more accurately divide areas

based on climate, soil, elevation, and other physical features that

truly distinguish it viticulturally from surrounding areas.

Sincerely,

Angela Mitchell

Mitchella Vineyard and Winery

2525 Mitchell Ranch Way

Paso Robles, Ca 93446