Comment #2

-----Original Message-----
From: Conde Cox [mailto:condecox@charter.net]
Sent: Wednesday, October 08, 2003 1:52 PM
To: nprm@ttb.gov
Cc: Earl Jones
Subject: Notice No. 17--RIN: 1513-AA75; 2002R-338P: Southern Oregon AVA

To the TTB:

Please accept this comment in support of the proposed new Southern Oregon
AVA for wine labels.

Professionally, I write about Oregon wine for various magazines, including Wine Press Northwest and Northwest Palate.  I have previously written about wine for a newspaper, and I am currently an applicant for admission to the London-based Institute for Masters of Wine.  Wine, and Oregon wine in particular, are my passion and the subject of my work.

It is my firm conviction that a separate label name for Southern Oregon wine is fully justified and that the area grows distinctive wine grapes that produce unique, identifiable wines.  Wines made from grapes grown in the Umpqua and Rogue River Valleys (which are proposed to be virtually merged, for purposes of this new label name) exhibit similar characteristics, and this is not surprising, given the nearly indistinguishable weather patterns that are found in these two areas.  In fact, Southern Oregon constitutes an appropriate and even necessary addition to America's list of identifiable viticultural areas, because wines from Southern Oregon are made from grape varieties that can not be suitably grown in any other part of the State, with the possible exceptions of that tiny part of the Walla Walla AVA that stretches barely into Oregon, or that parts of the Columbia Valley appellation that touches Oregon; but even wines made in Oregon's small part of the Walla Walla or Columbia AVAs are noticeably more herbal and exhibit far less black cherry notes on the nose and palate than wines made from the same grape varieties grown in Southern Oregon; in other words, Southern Oregon wines "in the glass" show their terroir-source, even in comparison to wines made in other parts of the Pacific Northwest from the same grape varieties.  One reason for this taste-flavor distinction must be the cooler nights at slightly higher elevation for Southern Oregon, as compared to Eastern Washington or the parts of northeastern Oregon that are also situated in or near the Columbia Valley..

To me, and, I would dare-say, to others who live in the southwestern part of Oregon, the term "Southern Oregon" is used to define a distinctive region that is bounded: (i) on the east by the Cascade Range; (ii) on the west by the Coastal Range (which is west of the Klamath and Siskiyou Ranges); (iii) on the north by ridge lines located barely south of Lane County, just to the southwest of Cottage Grove [near Drain and Curtin] that tend to deflect clouds and rainfall toward Eugene, where rainfall and cloud cover are substantially higher than in Roseburg and points south; and (iv) on the southern end, by the Cascade-Siskiyou connecting ridge line, which, to me, is perfectly defined by the Pacific Crest National Scenic Trail, which runs in this region on an east-west axis, just barely north of the Oregon-California state line.

It is important to realize for purposes of Oregon grape growing, that Vinifera grapes can not be grown east of the Cascades because of severe cold (brought on in part by high elevation).  In addition, fine wine grapes grown in the cool wet region to the north (ie, in the Willamette Valley) will nearly always be of the pinot family (pinot noir, pinot gris, and pinot blanc, all of which are genetic cousins), which have, not surprisingly historically been grown in the cool (but not cold) damp regions of Europe, such as Burgundy and Alsace.  Southern Oregon's finest wines are made from Syrah, Malbec, Cabernet Franc, or Tempranillo, which are varieties that have historically been grown in the warmer parts of Europe, such as the French Rhone Valley or Spanish Ribera del Duero.  To the far west, in the Oregon Coastal zone, quality wine grape growing would certainly encounter mildew and Pierce's Disease problems that would force growing techniques and varietal selection that would likely result in certainly very different if not even low quality wines, (which of course is the reason that there are no extant Oregon Coastal Zone wineries or vineyards, to my knowledge).

I use the term "Southern Oregon" in my professional writing to describe this region, and the use of this phrase in print, in my view, does not cause confusion, for the reason that people living in this area fully understand what the general boundaries are when this term is used, both in general terms and in the particular sense of distinctive wine making and grape growing.

Please approve this new AVA.  It is long overdue.

Condé Thompson Cox
Ph. 541 899 9557
US Mail: P. O. Box 1506, Jacksonville, OR 97530
email: condecox@charter.net
Deliveries: 705 East C St., Jacksonville, OR 97530