The US Appellation system
- Wednesday 1 April 2009
Mention the city of Augusta to most Americans, and they think of golf. But while Augusta, Georgia, conjures up magical memories from the US Masters tournament, it is Augusta, Missouri, that holds a special place in US wine history.
It was here, not in Napa or Sonoma, that America’s first American Viticultural Area (AVA) was granted in 1980. Consumers outside Missouri would be hard-pressed now to find a bottle labelled with the Augusta AVA. (If they did, it would likely be hybrid varieties such as Seyval Blanc and Chambourcin, or the native American red varietal Norton, also called Cynthiana.)
Today there are nearly 200 AVAs, half of them in California. Oregon has 16, Washington 10, and New York and Texas eight each. Add to that the 50 states and 1,000-plus counties considered to be political appellations – though not federal AVAs – and America is a crazy patchwork quilt of delimited, and often overlapping, regional demarcations that can mean nothing – or everything – to those who buy wine, and those who make and sell it.
It is not just in Europe that the ‘does place matter?’ debate is raging. Italy is reexamining its DOCG category, Champagne is extending its boundaries, St-Emilion’s classification controversy continues, and now the US has a ‘terroir’ issue of its own. Only here, it has nothing to do with wine quality or taste. Just 29 years young, the AVA system, the US
version of Appellation Controlée (AC), is experiencing growing pains.
Before the establishment of AVAs, domestic wine labels bore wordage that gave buyers only a vague sense of where the grapes were grown. Since the approval of the Augusta AVA, the US Treasury Department, under whose wide umbrella AVA regulation falls, had enjoyed a relatively easy time sorting things out.
While petitions typically take two years to wend their way through the bureaucratic process, there were few arguments over most of them, and little resistance by the
Treasury’s Bureau of Alcohol, Tobacco and Firearms (BATF) – later re organised as the Alcohol and Tobacco Tax and Trade Bureau (TTB) – to adding new zones to the official list.
Yet TTB is mainly a tax-collecting agency and not a terroir expert. It looksat maps, climate charts, soil photos and historical data submitted by petitioners, without ever setting foot in vineyards or tasting any wines. Its stated AVA mission?
‘These designations allow vintners and consumers to attribute a given quality, reputation or other characteristic of a wine made from grapes grown in an area to its geographic origin. The establishment of viticultural areas allows vintners to describe more accurately the origin of their wines to consumers and helps consumers to identify wines they may purchase.
Establishment of a viticultural area is neither an approval nor an endorsement of the wine produced in that area.’ If then, unlike in Champagne or St- Emilion, the AVA designation requires no winemaking standards to be met, what use is it to a consumer seeking out the stylistic traits and merits of a region?
TTB relies on the accuracy of the information provided in the petitions, and a public comment period during which the information can be challenged, when making its decisions on proposed AVAs.
Thus AVAs tell consumers that at least 85% of the grapes used to make a wine were grown in that AVA (15% can come from other areas), but don’t tell them about the quality of the grapes, the style of the wine, the harvest dates, the source of the remaining 15% of grapes,
or yields, and sets no standards for vinification or ageing.
A Napa Valley Cabernet Sauvignon, Willamette Valley (Oregon) Pinot Noir or Finger Lakes (New York) Riesling may have an implied image of quality based on the cachet of its AVA, yet a winery in one of these appellations could regularly bottle vinegar and TTB wouldn’t care. It would still quality for the AVA, and consumers wouldn’t know until after their purchase.
In the seemingly red-stamping past atmosphere in Washington, DC, it was a shock when TTB refused to okay what should have been a slam-dunk petition in 2007 for the creation of a Calistoga AVA in Napa Valley. The region is home to Araujo, Chateau Montelena and other top producers, and boasts historical importance in spades, plus distinctive topography, soils, climate and elevation.
TTB head administrator John Manfreda put a hold on the application (still in place as we went to press), concerned that a winery with ‘Calistoga’ in its name would have to change its labels, at some financial loss, because it did not use the minimum 85% Calistoga-area grapes in its wines.
Calistoga Cellars wines are made in Mendocino County, not Calistoga – not even Napa Valley – yet TTB, which insists its role is to negate consumer confusion about wine labels, suggested that Calistoga Cellars be ‘grandfathered in’ and be allowed to keep its label, despite not meeting the 85% Calistoga grapes requirement.
In protecting the winery’s business interests, TTB seemingly violated its own consumer-first rule, and endorsed a business-friendly philosophy. Yet who would not assume that Calistoga Cellars Cabernet Sauvignon is made from anything other than Calistoga grapes?
TTB responded to the Calistoga controversy by posting proposed Treasury rules Nos. 77 and 78, which halted approval of ‘nested’ AVAs – those proposed within existing AVAs (think Stags Leap District being carved out of Napa Valley AVA, and Chehalem Mountain as a subset of Willamette Valley).
Under the proposal, wineries established between 1986 and 2005 can continue to use brand names that are in conflict with previous TTB policies, as long as the label includes a statement clarifying that the geographic area suggested by the brand name does
not reflect the origin of the wine.
Brand vs place
The so-called ‘nesting’ proposal is particularly vexing, as it discourages drilling down to more specificity in AVAs. Take Paso Robles, which has petitioned TTB to subdivide its large self into 11 sub-AVAs that speak more directly to the styles of wine made from each region. TTB’s stall on the Paso Robles petitions, as well as that of Calistoga, doesn’t have a projected outcome, due to TTB’s withdrawal into its own shell, and possible changes President Obama’s administration might bring to the TTB office.
Manfreda opened a can of worms in asking, via his proposed rules Nos. 77 and 78, whether brand trumps place. Does commerce outrank authenticity? In 2008, he testified before the US House of Representatives’ Ways and Means Committee’s Subcommittee on Oversight in Washington, DC, and Congressman Mike Thompson challenged him on his handling of wine industry rulemaking.
Numerous wineries and more than 50 members of Congress, including Senate Speaker Nancy Pelosi and Senator Diane Feinstein, urged then-Treasury Secretary
Henry Paulson to scrap 77 and 78. Further developments are likely, though it’s fair to say the new government has more pressing issues resting in its in-tray.
America’s most important wine region, Napa Valley, has been particularly vocal in
protecting its place name, going after a ‘Napa’ winery in China, and Bronco Wines’ Fred Franzia, creator of the Charles Shaw ‘Two Buck Chuck’ wines.
Franzia’s Napa Ridge brand, which he purchased from Beringer Vineyards in 2000, was a blend of California grapes, but the majority of fruit was not grown in Napa Valley. The Napa Valley Vintners organisation convinced judges that the Napa Ridge label implied that the grapes were predominantly from Napa, when in fact they were not.
Now Napa Ridge wines comprise a minimum 75% Napa County grapes; why Calistoga Cellars isn’t held to the same criteria is a puzzle.
While ‘nesting’ AVAs are under threat, confusingly, AVAs can cross state borders, the most obvious being the Walla Walla and Columbia valleys, with a foot in both Washington and Oregon (see Decanter July 2008), and the Ohio River Valley, which seeps into four states – Indiana, Kentucky, Ohio and West Virginia.
At more than 6.5 million hectares (ha), the Ohio River Valley is the largest AVA, while Cole Ranch in Mendocino County is the smallest, at a mere 76ha. In Napa Valley, a conjunctive labelling regulation means all wines produced from its 14 sub-appellations must also
carry the Napa Valley name.
Thus a wine from the Howell Mountain AVA must also include the Napa Valley provenance
on the label. Wines designated simply as ‘Napa Valley’ are either blends from multiple sub-AVAs within the valley, or made by winemakers who decline to declare a more specific appellation. Paso Robles also mandates conjunctive labelling. In a 2008 letter sent to the Paso Robles AVA Committee, Robert Haas of Tablas Creek Winery wrote: ‘As for
AVAs within AVAs, the precedent has already been set in the US, since they
The larger AVA informs the consumer by determining the larger geographic location of the vineyard with which he will be more likely to be familiar. The smaller AVA determines the
more exact location of the vineyard(s) and their distinctiveness within the larger AVA. That is the way all wine producing countries in the world regulate their identifications of geographic locations to best inform consumers.’
Haas says he is not in favour of rolling ‘grandfather’ exceptions. ‘There is an established regulation for 1986 and before. It should be followed,’ he says. He suggests that producers who find themselves in conflict with new AVAs, who have COLAs (certificates of label approval) approved after 1986, be given time to bring their sourcing into line or change the brand name and/or label.
‘They are fraudulently representing the source of their grapes, and they know it,’ he says. Nick Frey, president of the Sonoma County Winegrape Commission, wrote to TTB, on behalf of 1,800 vineyard owners in Sonoma and Marin counties, claiming ‘it is difficult to have wording on the label that would avoid consumer confusion’.
He believes ‘grandfathering’ is problematic, arguing that ‘as the value of the AVA grows, the value of the brand can be inflated, as was the case for the Napa Ridge brand’. Again, he proposes giving such a brand time to comply or to create a new brand that does not conflict with a geographic region.
‘If a brand is well established before an AVA application is filed, then the applicant should file a geographic designation that does not conflict with the existing brand,’ he says. Whatever the result of TTB’s current navel gazing, sense of place must surely
outrank business sense, and wineries that have followed the rules since 1980 should be rewarded for fair play.
Most importantly, consumers should be able to look at a wine label and know where the grapes were grown; Calistoga Cellarstype obfuscation is a lie American wine lovers don’t need.