Issue link: http://winesandvines.uberflip.com/i/708909
August 2016 WINES&VINES 33 VIEWPOINT tees be "fairly balanced in terms of the points of view represented" and that the committee's ad- vice be objective and accessible to the public. When I first studied appellations of origin at the London Wine and Spirits Education Trust, I learned that appellation classification systems are designed to help consumers un- derstand wine origin. Consumers then can explore—and get excited about—wines at each level of the appellation hierarchy: from the largest to the smallest—country, region, dis- trict, village and vineyard, like the rings of a concentric circle. That hierarchical organization is lacking in the American system. Our AVAs range from multi-state areas like the Ohio River Valley (16.6 million acres, covering parts of four states) to the tiny Cole Ranch AVA (189 acres in Mendocino County, Calif.) to AVAs that par- tially overlap. Jess Jackson of Jackson Family Wines, dur- ing TTB's reassessment, recommended that the agency adopt a tiered AVA system with zones, regions and districts, similar to Australia's clas- sification of its geographical indications (akin to AVAs) into zones, regions and sub-regions. TTB rejected this proposal. At a minimum, TTB should require petition- ers to describe how their proposed AVAs com- pare viticulturally to other existing AVAs in the same geographic area and how the new AVA, in that context, will inform—rather than con- fuse—consumers. This lack of context is why I started filing multiple AVA petitions simultane- ously—to force TTB to consider the relation- ships among AVAs. I did that first with the Rutherford, Rutherford Bench, Oakville and Oakville Bench petitions and later with 11 peti- tions for nested AVAs (filed in 2007 and ap- proved in 2014) inside the 614,000-acre Paso Robles AVA. Vineyard designations Another major change that TTB should make is to formalize vineyard designations. Vine- yards are an increasingly important part of the hierarchy of a wine's origin. In the 1970s, ATF proposed to regulate vineyards, but the agency backed away from the idea because it seemed unnecessary. As a result, vineyards today have no officially recognized boundaries. On a wine label, a vineyard designation refers to whatever plot of ground the grower— or with the consent of the grower, the purchas- ing winery—determines. There is nothing to stop the expanded use of a vineyard designa- tion, even for land that is non-contiguous or under separate ownership. Additionally, the holder of a trademark registration to a vineyard name can use that mark for wines made from grapes grown elsewhere. Vineyard designations make good sense— and so did ATF's original 1976 proposal that would have required wineries or grapegrowers to notify TTB of their vineyard designations prior to using them on wine labels. The notice would tie the vineyard name to a particular property or contiguous properties so that, like an AVA, it can be found on the ground. TTB would then establish rules on how vineyard designations can be used on wine labels, for example, in direct conjunction with an AVA, no larger than half the size of the brand name, and always with the name "vineyard" to ensure ready identification by consumers. As with brand names, TTB would stay out of private disputes over vineyard names; those fights would be resolved by the parties, with or with- out resorting to the courts. Fortunately, TTB already has taken steps to resolve some potential conflicts over vineyard names by requiring, as it does for geographic brands, that vineyard designations that include AVA names can only be used on wines that qualify for the named AVA. Today's wine enthusiasts and wine critics focus increasingly on vineyard designations. Already there is talk about the grand crus and the premier crus of American wines. This sort of ranking is inevitable. I am not suggesting that