Comment 15

name=Paul Lukas
name=Winemakers LLC
Address1=PO BOX 1019
Address2=
City=Sunnyside
State=WA
Zip Code=98944

Comments=My company owns and operates two vineyards in the Yakima Valley AVA that total 344 acres.  One of these vineyards is within the proposed boundary of the Rattlesnake Hills AVA and one is just to the east.  I do not believe the petition establishes the proposed area as being significantly different from the surrounding Yakima Valley AVA and also believe the name is inappropriate for the relatively small geographic area it encompasses.  The petition compares the areas heat units with those of Red Mountain.  Red Mountain is already established as an AVA and has proved it is different by definition.  The data in the petition points more too how similar the heat units are to other stations in the Yakima Valley AVA rather than how they are different.  Further, I believe the statement that the proposed area is protected from the Canadian-Polar air is flawed.  Our vineyard (within the proposed AVA) suffered major freeze damage during the last two freeze events recording temperatures to -16 below zero.  Our vines were killed and needed to be replanted.  The Rattlesnake Hills are a range of hills and mountains that run east by southeast from Union Gap all the way to Benton City (about 45 miles as the crow flies).  The proposed AVA includes less than half of this area- mainly the western portion.  Conversely, there are several times more vineyard acres in the middle and eastern portion of the Rattlesnake Hills region.  I do not think the petition adequately establishes why the name Rattlesnake Hills should only apply to this small portion of the actual recognized mountain range.  Our larger vineyard is to the east of the proposed AVA and historically we have experienced annual differences in growing conditions; however, we do not employ different viticulture practices between the two farms.  Our experience shows that there are certainly unique micro climates within the Rattlesnake Hills as a whole, but certainly not geographically and climatically enough to establish an AVA within its own slopes.  I believe the petition does not adequately meet the standards required to establish this area as a separate and distinct viticultural appellation.