Comment 11

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:
 
The following comments are made with regards to Notice No. 47 for the proposed establishment of the Rattlesnake Hills viticulture area posted in the Federal Register, Vol. 70 No.104:
 
1.)   The boundaries of the proposed AVA are Arbitrary and not based upon any meaningful geophysical boundaries.
 
2.) The name Rattlesnake Hills describes an area larger than the proposed the artificial boundaries of the proposed AVA.
 
3.) The climate, geology, soils and general growing condition within the proposed area do not vary significantly from the surrounding areas.
 
In closing, it would it is apparent that this is not a defined growing area any more distinct  than its surrounding area, and seems to be more of a marketing proposal than a true distinct AVA. We see a detrimental effect upon the Washington State Wine Industry to allow such and arbitrary drawing of AVA lines.
  
Respectfully,

Mark Tudor
Tom Tudor
Tudor Hills Vineyards Inc.
Growers of Quality Washington Wine Grapes.