Comment 137

23 April 2007

Mr. Frank Foote 
Director, Regulations and Rulings Division 
Alcohol and Tobacco Tax and Trade Bureau 
Attn: Notice No. 71 
P.O. Box 14412 
Washington, DC 20044-4412 

Re: Opposition to Proposed Paso Robles Westside AVA 

Dear Mr. Foote:

I am Professor of Geography, Ecology, and Wildlife, Fish and Conservation Biology at UC Davis, and the geographical science expert of the Paso Robles American Viticultural Areas Committee (PRAVAC), whom has opposed the establishment of the proposed Paso Robles Westside AVA. My credentials are elaborated upon in PRAVAC’s statement of opposition, and in their petitions to establish 11 new AVAs within the existing Paso Robles AVA.

I have read all of the comments posted on the pending Paso Robles Westside AVA on TTB’s website. I write here to comment on Mr. Doug Beckett’s Comment 128.

In Comment 128, Mr. Beckett states that size is not a legitimate reason to disapprove the Paso Robles Westside AVA petition, referring to much larger approved AVAs across the country.  He then addresses the north, west, south and east boundaries he and his co-petitioners have proposed for the Paso Robles Westside AVA, stating that the northern, western, and southern boundaries are those of the approved Paso Robles AVA, and that the “fourth boundary, Eastern, is exactly what Dr. Rice wants to see, an ancient water shed, the Salinas River.” This refers to Dr. Rice’s Comment 129.

I found the above to be a confusing comment by Mr. Beckett, as the proposed eastern boundary of the Paso Robles Westside AVA is the current Salinas River CHANNEL, not the watershed. The SALINAS RIVER WATERSHED is huge (approximately 4,600 square miles in area; see map below), and it bears no relationship whatsoever to the proposed Paso Robles Westside AVA. The Salinas River is the longest of the CENTRAL COAST AVA rivers, and in that way, very similar to the large Sacramento and San Joaquin Rivers inland.  The Salinas River empties into Monterey Bay and the Pacific Ocean 11 miles north of the city of Monterey, then runs south-southeast through Monterey County and San Luis Obispo County for over 150 miles.  Its WATERSHED is about 10 miles wide and 155 miles long within the Coast Ranges. Approved AVAs within the Salinas River Watershed include not only the Paso Robles AVA, but the York Mountain, Hames Valley, Chalone, Arroyo Seco, and Monterey AVAs, among others.

I also want to point out that, contrary to Mr. Beckett’s assertion, the channel of the Salinas River is NOT ANCIENT, but very recent in origin, as shown by its current, perched location above the River’s true alluvial valley floor (to the east and south of the town of Santa Margarita), where it has carved a recent course along the Rinconada Fault, through soft rocks.

In Comments 94 and 129, Dr. Tom Rice, Professor of Soil Science at California Polytechnic University, San Luis Obispo, and the reported geographical expert for the Paso Robles Westside AVA petitioners, withdraws his support of the proposed Paso Robles Westside AVA, and states his opposition to its establishment. In his most recent Comment 129, Dr. Rice proposes a scientific analytical approach to define smaller AVAs within the Paso Robles AVA that is similar to the approach that we (PRAVAC, and myself as their geographical expert) have used. However, Mr. Beckett in Comment 128, has misunderstood what Dr. Rice stated in Comment 129 on a watershed approach. On pages 2 and 3 of Dr. Rice’s letter of comment, he states:

“I have studied the soils, geology and landform patterns within the Paso Robles AVA for over 20 years.  Over these years, I have discussed potential AVA subdivision scenarios with several winery and vineyard owners.  I suggested that the initial action to assist the subdivision of this large Paso Robles AVA was to produce major watershed maps of this area.  That is, use existing U.S. Geological Survey topography maps to generate digital elevation maps (DEM's) of all the major watersheds within the Paso Robles AVA.  For example, on  a large DEM of the entire AVA, delineate the watershed boundaries of Tablas Creek, San Marcos Creek, the Huerhuero River, the Estrella River, Paso Robles Creek, the upper Salinas River and the other major water drainageways.  Then, overlay environmental "layers" on this watershed map, including soils maps, 
geology maps, information on prevailing wind patterns, and other relevant 
climatic (precipitation and temperature) data.  After all of these watershed and environmental maps are prepared, examine them with winery and vineyard owners to determine whether any logical environmental and land use patterns emerge.  Finally, draw the final Paso Robles AVA subdivision boundaries using real environmental parameters (like watershed boundaries, soils maps, geology maps, and climatic zones), which do not exclusively use the "market-based" desires of individual landowners when designating the final AVA subdivision boundaries.”

Watersheds are typically used as defined geographical areas to look at (1) sources of sediments for the alluvial soils within them, (2) water quality conditions in their streams and rivers, and (3) aquatic natural resources, such as fish.  In reviewing the proposed Paso Robles Westside AVA and in determining the boundaries of the 11 AVAs that PRAVAC proposed, we analyzed all small and large watersheds (a) within the entire Paso Robles AVA and (b) in the area west of the Salinas River to arrive at distinguishing viticultural environments.  We analyzed all available published scientific information on geology, geological history, geomorphology, topography, climate, weather, soils, vegetation, surface hydrology, and ground water resources, as Dr. Rice suggests should be done, in drawing and examining AVA boundaries.

The science speaks for itself, and is reflected in the quite diverse viticultural environments of the proposed Paso Robles Westside AVA, from north (dry, warm and windy) to south (wet, cool, and sheltered), that do NOT support it as a viticulturally distinctive AVA.  I am in strong OPPOSITION to the approval of a Paso Robles Westside AVA.

Sincerely yours,

Dr. Deborah L. Elliott-Fisk, Ph.D.
Professor 
Graduate Group in Geography
Graduate Group in Ecology
Graduate Group in Community Development
Department of Wildlife, Fish and Conservation Biology
University of California, Davis
One Shields Avenue
Davis, CA 95616

Map of Salinas River Watershed