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Ralph at Tuthilltown

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About Ralph at Tuthilltown

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    Hudson Valley, NY

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  1. Ralph at Tuthilltown

    the biggest little micro distillery

    About the only one's who think of this franchise as "micro distillery" are the marketing guys at ABSOLUTE. I don't think the proposal would fly for any informed consumer and certainly not with the real craft distillers in the US who will see this for what it is. I don't think they are kidding anyone but themselves and the "give it to me cheap" market. When asked if the base spirit is actually distilled at the "local" site, with some coaxing the answer finally came, the GNS arrives at the site full strength and is bottled with local water. That is neither, "local" nor "craft". The fact is that Michaelangelo seems to have hit the nail on the head, it's a good demonstration that Craft Distilling is now a serious, legitimate member of the profitable spirits world. What was that phrase "Imitation is the most sincere form of flattery." Big producer investment in the "small brand" image is a semaphore, the concept of crafted artisan spirits has delivered its message to the big guns, and they are trying their best to emulate, simulate and obfuscate the Craft message. R
  2. Ralph at Tuthilltown

    Building a "Green" Distillery

    When striving for "Green Whiskey" remember it is not just about fuel consumption. Remember before you make "Green" claims that your spirits are contained in a heavy glass container, and that you are shipping your liquid across the country burning fuel the whole trip. Remember too, our carbon footprint is inherently broad, since fermentation creates substantial CO2. So careful when you tag your goods as "Green".
  3. Ralph at Tuthilltown

    STATES REGULATING BARREL AGED COCKTAILS

    The point of a "barrel aged cocktail" is that the whole cocktail is aged together and served out of the barrel, in most cases. Aging the non-alcoholic parts would not produce the same result. And the popular aged cocktails being prepared are spirits mainly, like a MANHATTAN. Putting juice or a mixer in an oak whiskey barrel would not produce the same result as putting the spirit (a solvent) into oak along with the other ingredients.
  4. Ralph at Tuthilltown

    STATES REGULATING BARREL AGED COCKTAILS

    The "barrel aged cocktail" is growing in popularity. Many craft distillers are putting their used oak barrels to use as promotional tools in on-premise accounts where the mixologist creates a cocktail, ages it in a recently emptied whiskey barrel on the back bar where it can be seen by customers, then serves it to consumers when it has taken on the rich qualities of the whiskey impregnated oak. Regulators in some States have noticed and are taking action to enforce Prohibition era laws, and are applying questionable precedents where no specific regulation clearly addresses the issue. Some alcohol control laws prohibit serving spirits "from a tap". This is State regulator territory, States control distribution. The State regulators’ oft cited basis for enforcement of such regulations is protection of the consumer. The server may be short changing the consumer on alcohol content if the spirit is not being poured directly from the bottle it came in is the logic. Some States are, in the case of barrel aged cocktails, claiming that aging spirits in oak is “manipulation” of the spirits and therefore falls under the definition of “rectifying” which requires a rectifier’s permit. It this is the case, every bartender and mixologist is breaking the law every time they manipulate the a spirit when they prepare a cocktail, or for that matter even put an ice cube or water into a spirit. And serving a pre mixed drink from a barrel is not serving “spirits” from a tap, it is serving a “cocktail”, they are not the same thing. Can we hear from the spirits producers and on-premise operators, barmen, mixologists, consumers? Some of the important questions which are being asked: How widespread is the practice of pre-batching cocktails in oak barrels, are you doing it, is it popular with consumers? Is there some State regulation which applies to this practice? Or is it not directly addressed in your State law and open to interpretation by regulators? Are regulators applying questionable legal precedent to regulating barrel aging cocktails in your State? Has your barrel aged program been challenged by State regulators? Was it resolved? How? State Regulating authorities are at a loss determining the scope of the practice and are eager to understand it. Some are reaching out to the trade to get basic data on barrel aging programs. Your responses and State alcohol law information will be very helpful. Ralph
  5. Ralph at Tuthilltown

    Certified craft -- setting the record straight

    A Master Distiller operates within the law. Basement hobby distillers may have the "distillation" part down, but they are not accepting the full responsibility for the craft activity. I used to run up against this same logic in the climbing business. Highly experienced rock climbers often hire out to beginners as "guides". They sometimes do not get a guide license and they rarely carry insurance for their clients. Just being really good at something is not enough. A "Master's" job, like a climbing guide's, includes the protection of everyone involved, protection which extends beyond immediate physical safety to include a safe conclusion to the undertaking and a realization that accidents happen and it's the "Master" or the "guide" who must protect his charges in the event of accident and injury. What happens when something goes wrong, who is "responsible". If a basement distiller without a license blows up his house or starts a fire which jeopardizes others, his neighbors, the community, an injustice? When a "home distiller" operates without a license, uninspected, uninsured against accidents, who ensures responsible practice? There may be no accepted course of study or academic award or formal process in place for determining who is a "Master Distiller", but it is my opinion the absence of any formal program or criteria does not change the fact that the title "Master" is not one which is self-awarded, it is recognition from some higher authority in whatever category. The term "Master" includes a much broader field than simply operating a still. It includes safe legal operating practices, staff safety considerations, insurance, ensuring product is safe, having professional inspection of systems. This is NOT making beer or wine, it generating volatile gas and no matter how many precautions you make to keep your little home distilling set up safe, it is NOT SAFE, accidents happen.
  6. Ralph at Tuthilltown

    Residences in conjunction with Distilleries

    No debate on the ambiguity, sometimes being an advantage. May I suggest, Mr. Dunbar, that you put your suggestions to the TTB. My personal preference is for an interpretation based on the degree of connection. Not an attorney, but my call is that if the building is not connected (by wall, breezeway, roof, fence, etc) to the building which is the actual distillery building, that separation is sufficient to determine it is not "connected" with a home or residence. We'll see what comes of the TTB discussion on the topic.
  7. Ralph at Tuthilltown

    Residences in conjunction with Distilleries

    It is true that phone comments are not to be taken as THE resolution. But they can bring contradicting opinions to the front, especially when the caller can identify the source of the misinformation as they work their way up the ladder of responsibility. The TTB is addressing this issue at an upcoming meeting with their Cincinnati office in DC shortly. The ambiguity is deliberate apparently, so that they can determine the extent of "connection" and determine on a case by case basis, this is true. I believe there is a "one size fits all" solution to the text problem. We'll stay close to this and see what comes out of the upcoming TTB meeting. The TTB representative in Regulatory office agrees the language is ambiguous, they are addressing this.
  8. Ralph at Tuthilltown

    Residences in conjunction with Distilleries

    Thanks Chuck. I retract my last comment suggesting this be put to rest, obviously the interpretations being received from Investigators at TTB are not in conformance with practice. I agree that the ongoing polite but not necessarily deferential dialogue with the respondent at TTB is important. It will form the basis for your appeal if you must file one. But also, the previous suggestion that you pick up the phone and call the TTB directly is a good one, and take notes on the conversations. I stand with Chuck on this, the law and precedent agree: there is no prohibition against having a DSP premises on the same parcel as a residence, a domicile, a house. There are numerous examples of licensed DSPs with residences on the same lot, not connected to the distillery building or rickhouse or other of the "licensed premises". And this is exactly the kind of matter the AMERICAN CRAFT DISTILLERS ASSOCIATION is organized to address.
  9. Ralph at Tuthilltown

    FET BILL ONE PAGE TALKING POINTS

    The most effective lobbyist is the one who is a True Believer in the cause they're pitching. It's your business, your staff, your distillery; no one will be as passionate and dedicated to increasing its potential for success then you will. Give me engaged activist constituents over high paid lobbyists any political day of the week. State or Federal level, get on the phone, type a letter and mail it or Express it to your State and Federal Legislators. Make the introduction, then keep up a regular correspondence describing the wonderful things that Craft Distillers are doing for your home State and for the National Economy. It does take time, persistence, tenacity and determination but it IS possible to move the wheels of government even if only in small incremental steps. First step is to let them know you exist, you pay taxes and you vote.
  10. Ralph at Tuthilltown

    Certified craft -- setting the record straight

    Thanks Bluestar. Indeed, the original definition we composed a couple years ago allowed for addition of botanicals and other processes that "substantially change the character of the spirit" when GNS is used as a base. Some argue that fermentation is a basic requirement for a "craft" operation, but I'm not so sure since there is craft and skill in the combining of botanicals and other materials. It seems most agree with criteria which includes distilling in a still and change of character when using GNS. You are correct that "rectification" includes distillation. In any case, to manipulate the spirits a DSP permit from the Fed is required, regardless the various State license categories.
  11. Ralph at Tuthilltown

    Certified craft -- setting the record straight

    My personal opinion is that fermentation is a critical aspect of the craft. However, the ACDA and most craft distillers agree that the bottom line is a double line: the BASIC PERMIT and the STATE PERMIT. The question: "Must a craft distiller ferment his own mash?" is open to discussion, but at this point the main distinguishing fact separating rectifiers and blenders from Distillers is: a Distiller distills.There are a number of distilleries opening in partnership with brewers who prepare their mash. For some it is a necessary step, jobbing out the fermentation due to space prohibitions and equipment shortages. There is certainly craft in the combining of botanicals for gin. It is an ongoing debate.
  12. Ralph at Tuthilltown

    FET BILL ONE PAGE TALKING POINTS

    Thanks Brad. What about the rest of the craft distillers? Are you all on the phone with your Congressmen/women and Senators, are they all on your calendars for a visit to your distilleries? Have you primed all you employees with the reasons they are important to the economy? It is unlikely that Legislators will set aside enough time, if at all, to visit more than one distillery site; so any one who succeeds in getting their Legislator to agree to come to the distillery and learn about craft distilling should reach out to all the distillers in their State and make sure they are there in force, with their tax paying, VOTING employees to make the point. Come on folks, this is going to save you a ton of money if we're successful. GET TO WORK.
  13. Ralph at Tuthilltown

    Certified craft -- setting the record straight

    My opinion on the "Master" recognition: it is exactly that, a "recognition" of experience, education and determination. It is not a title one takes upon oneself. It is an awarded title, not self-assigned. It's inappropriate for a person to take on the title: Master Electrician, or Master anything without some qualification from a recognized source. Of course you could put "Master Electrician" on your card and sell yourself as such, and it might work, right up to the point you must convince an insurance company to insure your work or the house you wired for your buddy burns down.
  14. Ralph at Tuthilltown

    Jack Daniel's Rye is now "spirits distilled from grain."

    These points were made to the TTB Staff at the recent DISCUS LEGISLATIVE CONFERENCE in DC. The TTB agreed the Standards of Identity need updating, but they may not introduce that change it must come from a petition for change. Unfortunately there is no "form" for such a petition. It must be composed with the best explanation of the justification. As Chuck points out, it is a long process. That does not argue for continuation of inaccurate definitions, many of which handcuff creative new distillers' innovation. While it is true that the law specifies no time limit, the actual text of the Standards of Identity is less than exact, the definition of "whiskey" reads: Class 2; whisky. “Whisky” is an alcoholic distillate from a fermented mash of grain produced at less than 190° proof in such manner that the distillate possesses the taste, aroma, and characteristics generally attributed to whisky, stored in oak containers", the argument has been made that whiskey put into a barrel overnight would not take on the "taste, aroma, and characteristics generally attributed to whisky", but that is a subjective call and the TTB has not enforced it. The argument could be made that the requirement for typical "whiskey-ness" characteristics comes before the requirement that it be stored in oak containers, so the "taste, aroma and characteristics" would be generally attributed to the raw spirit, unoaked. Regardless the strength of the arguments, the distillers in the meeting strongly requested the TTB make some decision on this matter. But the action must be taken by a DSP in the form of a petition. That petition, if launched, should apply to the entire STANDARDS OF IDENTITY, and not just the issue of oaked or unoaked whiskeys. It will be a long and difficult process, but it should begin.
  15. Ralph at Tuthilltown

    LOWER FEDERAL EXCISE TAX, ACT NOW

    Take a look at the attached One Pager on the proposed Craft Distiller Excise Tax discount. Then contact your Federal Legislators and educate them. INVITE YOUR SENATOR AND CONGRESSMAN TO SEE A WORKING DISTILLERY WHILE IN THE DISTRICT FOR SUMMER BREAK, invite them to meet your voting/taxpaying staff, sample your Agricultural products and witness the visitor traffic you generate. Let them know the nascent American Craft Distilling industry would like parity with our Beer and Wine making cousins' discounted Federal Excise Tax rates. Check out the attached. craft spirits parity one pager 73013.pdf
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