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grehorst

Get your Federal Permit? How long did it take?

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Before you go making stuff you might want to be sure you're cleared with the Dept of Ag depending on your state. They can have a say as well.

Edit:

For PA, Feds was the long, but easy part. We had to do the following:

  • Zoning - conditional use, township approvals
  • Dept of Transportation - Driveway Permit
  • Federal TTB App
  • Building Permits/ Inspections/ Occupancy Approval
  • State LCB
  • PA Dept of Agriculture for the manufacturing side
  • FDA Registration
  • Health Dept for the tasting room, which also required getting the well registered with the state Department of Environmental Protection

The last one was the worst and literally strung us along for 360 days. Long story.

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We applied 9/22/2016. DSP received 03/27/2017

186 days. <_<

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Congratulations Allan.  I see you are in VA.  Where will your distillery be located.  We are located in Manassas, VA.  Good luck.

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Approved today, 214 days.

Actual review and request for corrections took 11 work days.

On January 1st most applications were reassigned to new reviewers. I got caught up in that. Previous reviewer helped me get to new, but only after I asked.

I was asked for six corrections/additional info. All six were easy...add compass rose to drawing, add size/square footage of operational areas to text description, etc.

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Just submitted ours yesterday! hoping Moonshine scenario above is the new norm- 72 days! but not holding my breathe!

----

 

 

Update. We just received approval! 13 days! There is hope!!!! Thanks TTB! Lets make some BOOZE!

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Just got my DSP today, filed on May 10th I did the app myself without any attorney help, took 2 months and 15 days I am stoked now waiting for TABC which would not submit my package until they got word that my TTB was complete. Just talked to them and paperwork has been sent off to the state. Getting real now !!!

 

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Filed on Mar 6
Approved on Jul 29th
145 Days. Seemed to be stuck, but David Dunbar managed to get it moving
Now trying to beat Bill's challenge and score a dinner

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Application submitted 8/21/17

Approved 8/24/17

I don't know what leprechaun wearing horse shoes and dressed in lucky rabbits feet I stumbled across.

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Bartletts Distillery, Montgomery County Texas.

Submitted: 10/07/2017 10:00 AM CST , registered into TTB on 10/10/17

Approved 01/18/18

100 days

Edited by Bartletts Distillery
Update with latest info

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West Branch Malts, Brunswick OH

46 days.  This is a special case in that we are building a distillery inside a malt house.  Dave Dunbar did all the heavy lifting on this one.  There is a separate thread about the malt house where I will post more information so I don't sidetrack this thread.

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51 days to receive DSP approval

Filed Nov 1 approved December 21

if interested here are the particulars

- No consultants used

- No additional questions or submissions requested from TTB

- In a rural area, DSP in building on the same 22 acre plot of land as our house (109 feet apart)

- Owners US citizens but lived out of country in last 5 years (required 10 yr background check)

Now the real work begins!!!

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Almost every application gets a deficiency email. The last two DSP applications I filed for clients received requests for corrections (minor stuff) within 30 days of filing. My brewery applications are taking longer. Wineries are wholesale/import are pretty quick. hope that helps.

John Springer
john@ttbhelp.us
www.ttbhelp.us
631-331-3334

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This literally makes me stomach clench every time I see a reasonable turnaround, while ours took +/-270 days....  but, we're doing ok :)

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I've occasionally warned against taking seriously times given in this thread.  TTB publishes average times.  The most recent was 88 days for a DSP, which is certainly an improvement over the time it was taking a year ago, but I don't put much stock in averages.  The mean means little, pun intended I guess, unless you can also describe the distribution around it, i.e., the range, mode, and median.   Averages are subject to statistic trick - you know, liars and damn liars.  If TTB wants to lower average times, each month it can  deliberately process one or two  to completion quickly.  Presto, the average  gets lowered with no real improvement in service.  I'm not saying, and do not mean to imply, that TTB does this; I'm saying averages don't mean much.  The same applies to times people report here.  They are isolated instances;  a fews dots on a graph.  They can create unreasonable expectations and fears.  

So, I don't advertise times because it can be misleading.  Yes, most applications are getting reviewed more quickly these days.  But that does not mean they all are, and the date that a specialist first picks up an application is crucial.  TTB deals them, to the specialists, like cards.  Get a specialist who is quick and you can get a request for correction, sometimes, but not often, within two weeks, as I did a couple of times in the last two months.  So what happened?  In one of those two instances, TTB's  secure email system failed to make delivery of a response to a request for correction and there went my chance for glory :-).  I say that in jest.  To to be very clear about the responses within two weeks, - that was not due to my competence  as a consultant.  It had only to do with the luck of the draw.  I could have submitted a half complete application and got a response in the same time.  So could you.  If either of us gets a different specialist, it may be two months, and if we draw one who is retiring soon,  all bets are off.  

Jessica describes a horror situation.  No application should take as long as hers did.  Hers was the outlier.  As a consultant I get some outliers too.  Hopefully not that long, but can't I claim it will not happen.  I can't.  

I'll add, not only do I not advertise times, I don't advertise period, unless these responses on the forum are advertising, which I guess they are, but I make them as a return to an industry that makes my business possible.  When I retire again, which, as I promise myself, I will do someday,  I will probably keep on answering questions on these threads.  You guys have been good to me the last few years.  I appreciate that.

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Valid point on the averages, I hadn't really thought of it to that extreme. As it was, the 'average' estimate was 6 months when we submitted... and you can't 'bother' them until that time has lapsed. At that mark, I started pestering... it took another 2.5 months for them to even look at it. Then it was like 2 small tweaks and everything was fine. Fortunately, we were prepared for the full 6, so while 9 sucked, it didn't blow us out of the water. 

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Jessica, your experience describes why one can't rely on the times people list here. 

As to "bothering" TTB, I've got some sympathy for their position on that.  The rule about not calling until the average time has elapsed is intended to isolate the specialist from repeated distractions that contribute to increase processing times.  I also have sympathy for the specialists who are buried in virtual paper.   And, I have sympathy for management which is told, repeatedly, by congress, that it must do more with less.  At some point that is not possible. 

However, I have less sympathy for management's failure to devise a way of triaging applications, like yours, that only require a couple of tweaks from those that require, shall I call it, major surgical repair.  I also have less sympathy - perhaps little sympathy - for a managerial style that puts specialists in fear of minor errors, yet does not put a stop to the systemic inconsistency of one specialist demanding what another prohibits in responses to the information required for the application.  The NRC is badly in need of a (1) a sense of materiality and (2) reasonable  internal controls, which only management can impose, that require information that is consistent with the regulatory scheme in parts 1 and 19.  It appears that this is now left to the  imagination of specialists, who, even with the best of intentions,  lack both (1) the perspective and (2) the time to develop the perspective, that is needed to determine whether the information provided in an application is material to approval.    And yes, if asked, I can certainly give specific examples of the NRC's fundamental misunderstanding of the scheme of regulation that is in place.

Finally, the physicist Richard Feynman once said, " If the professors of English will complain to me that the students who come to the universities, after all those years of study, still cannot spell "friend," I say to them that something's the matter with the way you spell friend."  TTB's annual report says that 75% of the applications they receive require correction.  I'd apply the Feynman rule to that.  We'll see if the new and purportedly improved and now delayed permits online system corrects the situation.  I suspect it will not.

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Jessica, ours took 11 days more than the advertised average time of 270 days (when we submitted).

What dismayed me was the permit took only eleven days for corrections and to issue...after someone actually looked at it!

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To Jessica and Falling Rock,

Thank you for sharing your experiences. I am sure that our (relatively) short approval time was in part from the experience agents have received from processing previous applications like yours. For that I do honestly thank all the pioneers ahead of us in the game. 

As was pointed out on averages, we are just one point on the graph. I would in no way imply that anyone else could expect a similar timeframe. I did feel it important to post our data point for others to see. Our application like I am sure most, had some straightford parts and others that were a bit tricky. I humbly say that the only special skill I claim is a little familiarity with government bureaucrats. I spent 25 years as a consultant in another heavily regulated industry (aviation) and learned to speak federal bureaucracy......

Like most startups we are working with a budget so we made the decision not to use a DSP consultant for the application.  In no way do I mean to take away from the value of a good consultant, we justed decided to save our consulting budget for assistance in production issues after the DSP approval.

We must have done something right because we were part of the minority of applications that did not generate any correction requests. We simply reviewed, rechecked and rechecked again the submission. 

Thanks to all in the forum for ideas we have received during the last few months.

Tim

 

 

 

 

 

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