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DSP Site Access Requirements?


Trevor

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So it's starting to look the the best location for the DSP on my land is down my private gravel road, across a creek and up a hill. In bad weather it may be difficult to reach.  I don't see anything specific about DSP access in 26 U.S. Code § 5178 but it does say "The Secretary shall prescribe such regulations relating to the location, construction, arrangement, and protection of distilled spirits plants as he deems necessary ".  Anyone know of any issue of accessing a DSP via a trail or across a creek?

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What size of a distillery are you looking at operating, and what kind of products are you planning on making?

It sounds like a nightmare for getting trucks in to load/unload, customers back to buy your product, getting trash/recycling, spent mash off-site. Not to mention the cost of running electricity back that far, is three-phase available? 

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Tom - We are starting pretty small (100 gal stills) and we'll start with Rum and ethnic specialty spirits. The gravel road is about 600 ft long. Up to this point I've been looking at siting the DSP next to the road but that site presents a lot of hurdles : floodplain regs, foundation to bring first floor above floodplain, constrained building area, etc.  Pretty much once we have the small building but there we could not do any additions.  The site down the gravel road has issues like accessing the last 100 ft and utilities. But the cost is a bit of a wash because the cost of running the utilities is less than the cost of raising the foundation 2 ft above the floodplain. The gravel road site also allows for no constraints on growth. The alternative route may be to build a super tiny distillery near the road and a builder building down the gravel road for storage and move operations if things take off.

 

Whiskey: We won't know for sure until we submit for permits but in my state agricultural buildings are exempt from the fire code. If I was rolling in dough or if the distillery does well then there is actually a 30" watermain all along the gravel road site.

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Re: TTB requirements - TTb will never see the road until after the application is approved, so the question may be moot.  

However, I see nothing that would allow TTB to deny the application based on the fact that in bad weather they have to walk a half mile from the parking area rather than 50 feet.  I see no general  requirement that would require that you plow snow, for instance, or fill potholes, or otherwise ensure that TTB can drive to within a certain distance of the door.

When TTB approves variances, etc., the question is whether approval would "hinder the effective administration of this part."  I'm tempted to argue that it is important  that TTB uses this provision, because it shows that it is concerned with, and considered, hindrances when it wrote the regulations.   Thus, since it considers hindrances, and did not include this in the provision re: construction, etc., hindrance or in convenience should not be considered in deciding whether to approve or not..  

Then I think about putting a DSP in a treehouse.  Hmm.   

I think TTB assumes that, for your own purposes, you must provide reasonable commercial access.  I think it assumes that such access will suffice.  I also think that if the local development department and fire marshal approve, TTB has no grounds to deny.  But not in a treehouse, please.    

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Everything you will end up needing, molasses, grain, barrels, equipment, bottles, all comes freight. What might seem like a short cut now may hinder your ability to even operate at some efficiency.  Hard to meet the freight elsewhere when the still is running. Oh right, he's gonna be there between 10-2. Sure. Or u have to spend time moving things again cause you can't get them delivered, not to mention a fork lift here and a fork lift there. Here a fork there a fork everywhere a fu#% f%#k. Oh then when you have to ship something. Like pallets of booze to your distributor.  Think it through real good   Pretty easy to blow through several pallets of any fermentable in a month. Even at 100 g batches. With all the friggin cleaning that needs to be done, I'm pissed when simple things like a delivery, take all day. 

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