Comment 7

-----Original Message-----
From: Bill & Jill denHoed [mailto:winefarmer@amerion.com]
Sent: Monday, July 18, 2005 10:19 PM
To: Rulemaking, TTB
Subject: Proposed Rattlesnake Hills AVA Comments
Importance: High
7/20/05
 
Chief, Regulations and Procedures Division
Alcohol and Tobacco Tax and Trade Bureau
Attn: Notice No. 47
P.O. Box 14412
Washington DC, 20044-4412
202-927-8525 (fax)
nprm@ttb.gov
 
Dear Sir/Madame:
 
My name is William denHoed. I have been cultivating vinifera grapes for wine since 1979 on the foothills of the Rattlesnake Hills. I am located north of Grandview Washington, above the Roza Canal, on the very foothills of the Rattlesnake Hills. My family and I are currently farming over 1000 acres of premium vinifera grapes for wine for several prestigious, well known Washington wineries. I have been farming one of the vineyards since 1987 under the name “Rattlesnake Acres” and in 2001 started operating the same vineyard under the name of “Rattlesnake Vineyards LLC“. These are general background comments.
 
The following comments are made with regards to Notice No. 47 for the proposed establishment of the Rattlesnake Hills viticultural area posted in the Federal Register, Vol. 70, No. 104: 
 
1.      Rattlesnake Hills Name: The USGS maps for Yakima and Walla Walla (scale 1:250,000) clearly show that the Rattlesnake Hills is a range of mountains that extends from approximately 121:30 west longitude to 119:30 west longitude. This is well beyond the east boundary (120:00 west longitude) for the proposed Rattlesnake Hills AVA. In addition, historical and current local use for the name Rattlesnake Hills applies to a range of mountains that delineates the north boundary of the entire Yakima Valley, including to its extreme east end. The tallest peak in this range, locally referred to as Rattlesnake Mountain, is located to the east of the proposed east boundary line. Finally, when ATF published the Yakima Valley AVA (Federal Register: Vol. 48, No. 65)  on April 4, 1983, it used the Rattlesnake Hills crest to delineate its northern boundary from Wapato Dam in the west to Red Mountain in the east where the Yakima River runs north between the Rattlesnake Hills and Red Mountain (119:30 west longitude). For these reasons, the use of the Rattlesnake Hills name should not be permitted for the name of the proposed AVA because it is not consistent with published and local use of that geographical feature and is not unique to the proposed boundaries of the appellation. 

2.   Boundaries: The east boundary of the appellation (120 west longitude and Bonneville power lines) is artificial and unrelated to any unique geographic, climatic or soil characteristics. The geographic, climatic and soil characteristics are the same on both sides of the boundary and in fact continue east many miles to Red Mountain. 

3.   Climatic Differences: 

a.	Heat Units: The proposed AVA cites heat unit differences between various neighboring WSU-PAWS weather stations inside and outside of the proposed AVA as justification for climatic uniqueness. In fact, the difference of 200 to 300 heat units between stations within the proposed AVA (2683 and 2870) and the cooler WSU stations in Prosser (2552 and 2554) and the warmer stations (Parker to the west and Badger Canyon to the east) are simply not significant or defining. Year to year fluctuation in heat units for individual stations can be 200-300 units as evidenced by comparing annual data for these stations in1998 and 1999. These differences simply illustrate the effects of varying local topographies and agriculture, elevations and micro climates over the wide area covered by the PAWS network. In fact, the cited differences in heat units argue against their uniqueness because of the large amount of variation throughout the Yakima Valley and in the vicinity of the proposed appellation. Why is one of the warmest weather stations outside of the appellation only one mile away and the coolest station only two miles away?

b.      Winter Cold: The claim that the proposed Rattlesnake AVA is protected from artic air masses and cold temperature vine damage is simply not true. During the last two cold events (1996 and 2004), vineyards located inside the proposed AVA sustained as much damage as Yakima Valley vineyards located outside of the AVA.  Cold damage in the Yakima Valley is primarily an elevation effect, with higher elevation sites consistently showing higher temperatures and lower damage regardless of the neighboring terrain. Damage is consistently higher below the 850 foot contour than above it. This is the reason why the vast majority of vineyards and fruit orchards in the entire Yakima Valley, along with spring frost avoidance, are planted between the 850 and 1300 foot elevation contours. 
4.      Soil Types: The petition claims that the soils within the proposed AVA are unique to the AVA and ‘seldom found elsewhere within the Yakima Valley area’. That is simply not true. The soil surveys for Benton and Yakima Counties clearly show that there is a band of common soils that run the length of the north side of the Yakima Valley from Union Gap to Red Mountain. The primary soil types between 500 and 2000 feet elevation are silt loams derived from wind deposited soils (loess), that are level to moderately steep, shallow to moderately deep, well drained with a mean annual temperature of 50 degrees Fahrenheit and annual precipitation between six and 12 inches. These soils typically are underlain by a calcareous hardpan (caliche), which is in turn underlain by basalt. They include Warden Silt loam, which accounts for over 60% of the soils in the 500 to 2000 foot elevations, with lesser amounts of Shano, Burke, Esquatzel and Kiona silt loams. Again, there is absolutely nothing unique about the soils used for grape growing within the proposed Rattlesnake Hills AVA compared to the rest of the Yakima Valley.  

5.      Wine Labeling: As indicated in the proposal, there is only a little more than 1000 acres of wine grapes within the proposed boundaries and only about 17 wineries. However, the Yakima Valley AVA contains at least 10,000 acres of wine grapes, most of which are grown in the vicinity of the Rattlesnake Hills east of the proposed AVA boundaries and under the same geographic, climatic and soils conditions detailed in the Rattlesnake Hills proposal. In addition, there are another 30 wineries within the Yakima Valley and 280 wineries within Washington State, many of which utilize grapes from the Yakima Valley, but outside of the proposed appellation. By approving the Rattlesnake Hills appellation as proposed, TTB would be depriving these many growers and wineries from using the Rattlesnake Hills designation for their grapes and on their wine labels. 
 
For these reasons the proposed Rattlesnake Hills Viticultural Appellation do not meet the standards established by the ATF and should not be permitted. The name is too restrictive for the limited area of the appellation and the claimed distinctive geographic, climatic and soils characteristics cannot be supported by fact. 
 
Respectfully, 

William denHoed