Here is a copy of the comments that I submitted to our governing body, the Tax and Trade Bureau (TTB, formerly the ATF) on the subject of a proposed American Viticultural Area (AVA). The region described in the proposal radiates 2 or 3 miles around our vineyard site and it has been an obvious candidate for an AVA for many years. This version of the proposal was the most organized (and funded) of the 2 or 3 attempts prior to this. Each time, the discussion of the actual name drew spirited debate and was never resolved. This time, the debate was sidelined altogether. It's exciting that it is moving ahead but I'm not sure if we'll be adding the name to our label per the comments below.
From: Tom Farella [mailto:firstname.lastname@example.org] Sent: Friday, December 15, 2006 3:45 PM To: Rulemaking, TTB Subject: 'TTB Notice No. 68'
I would like to comment on the proposed Tulocay AVA that is up for consideration.
Our family has been growing wine grapes in the region for over 26 years. In fact, our vineyard is cited in the petition. There are few areas in the Napa Valley that are as easily defined as the "Tulocay" area for this purpose and I fully support the definition of the area.
I disagree, however, with the name "Tulocay." While there is a historical description of Rancho Tulocay and a few notations on various maps of this historic artifact, everyone in the wine trade has described the region (with identical boundaries) as "Coombsville." It has been the regional reference to the area east of the town of Napa largely owned by Nathan Coombs, one of the city's fathers. The name "Coombsville" is the common neighborhood description for real estate, references to the area by the main local paper, the Napa Register, and the greater local public as well as a grape growing area. The petitioners chose to ignore this obvious choice because they didn’t like the sound of it. Requests on my part to discuss the matter in our informal committee meetings were dismissed by the petitioners.
My feeling is that we should stay true to the requirement that the “area is locally and/or nationally known by the name specified” which is clearly “Coombsville.” It has been cited in wine books and publications for years. A recent article in Wine and Spirits Magazine discusses this exact AVA proposal, all the while referring to it as Coombsville. If the proposal proceeds with the name “Tulocay,” I strongly endorse the addition of “District” to the named AVA. To call it simply Tulocay would cause a great deal of confusion with the longtime brand Tulocay Winery. Many of the Napa Valley AVAs have “District” attached (Stag’s Leap District, Oak Knoll District, Spring Mountain District, Chiles Valley District) which better describes a small area within the Napa Valley. Our vineyard and winery are located at the very heart of the proposed viticultural area and I would be disinclined to add simply “Tulocay” to our label. I find that it would be very confusing for the consumer to see our brand and Bill Cadman’s Tulocay brand on the same label.
Please consider these comments for the proposed ruling and I hope to see comments on this point from other growers and wineries in the region. I want to emphasize again that I fully support the proposed viticultural area but believe the name should either be “Coombsville” or “Tulocay District” to avoid confusion.
Farella-Park Vineyards LLC