Melkon Khosrovian

Jorg is in (see list) and I've left a msg for Fritz. Had a call on this subject with an a Washington DC attorney (lots of industry clients/lobbying) who spotted our discussion and wanted to weigh in with basically the same concerns -- that DISCUS and leaders in beer/wine would not make passing our proposal easy. Can appreciate DISCUS's concerns, but am not sure on what basis would brewers and vintners oppose small spirits makers gaining the same reduced tax structure as small makers in their own industries. He also mentioned that there are rumors to raise excise taxes in 2009. If that's the case, then our timing for trying to create a lower tier may be ideal. Lowering taxes by an insignificant amount for the little guys will make passing increases for larger producers much more palatable for most elected officials, especially as most now have one or more spirits producers in their own states. What do other supporters of this proposal think?

On the numbers front, the TTB has some very broad proof-gallon numbers on its web site. Our previous numbers were fairly close to the mark, but failed to take into account non-taxed withdrawals for exports and military sales. Here's what I managed to pulled out for us to analyze: SPIRITS WITHDRAWALS ..................2006...................2007.............Trailing 12 Months ................Jul-Dec...............Jan-Jun............Jul 2006 - Jun 2007 Taxable.....128,984,087........134,949,392.....263,933,479.......72% Tax Free......50,973,041.........53,153,677.....104,126,718.......28% Total..........179,957,128.......188,103,069.....368,060,197 Could someone run a quick analysis on how much revenue small producers add to the pot based on the above (most current TTB) figures?

Spoke this afternoon with TTB's tax specialists in all three alcohol categories to see how we can best implement this proposal if we manage to pass it. (Special thanks to Cindy, Amy and Amy from the TTB -- you were incredibly helpful!) Here's the structure that seems to be in place as best as I could gather from my conversations: - Beer: producers select a size category at the beginning of the year and pay the appropriate rates (full, reduced); if they go over, they begin paying the higher tier; there's an annual review to project and select an appropriate category - Wine: producers select a size category at the beginning of the year and pay the appropriate rates (full, reduced tiers); if there's a chance to go over reduced tiers, producers pay full rate and file for refunds at the end of the year From the above, the beer industry's structure seems like the best financial option -- pay as you go and as you get bigger. It implies that we'll need to keep running tallies of withdrawals YTD in case we go over, but that's something all of us should have at our fingertips anyway. Thoughts?

I think that $2.70 is a perfectly reasonable and defensible rate. Here's why: - It represents 20% of the full spirits excise rate, which is higher than the lower wine tier at 18% -- we could even go even lower to $2.43 and match wine's 18% rate - Now that we have some rough numbers, the tax loss of 0.23% seems minuscule compared with its potential benefits to spur the sector's growth - Impact on much larger, more efficient competitors will likely be similarly minuscule Unless we get some radically different stats from the TTB that would skew the above figures, I think we should stick with our 20% lower tier not only for the above reasons, but also because how expensive it has become to get our products on and off shelves. I bet that every single one of us could use the extra $20/cs for marketing support.

Now, on to analysis... According to Bill Owens' back-of-the-envelope math, all 150+ small spirits producers in the U.S. (including some large ones like Tito's and St. George), account for less than 500K 9L cases sold per year. By the Distilled Spirits Council's stats, all spirits sold in the U.S. accounted for 177 million 9L cases in 2007. That puts small producers at 0.28% of the market (vs craft beer, which is 3-4% of the overall beer market). If we get our proposal passed, the net revenue loss would total $10 mil or 0.23% of all federal excise taxes collected from spirits sold in the U.S. Here's how I calculated it (someone please check my math -- it's Friday night and I'm sleepy): ......................................Small U.S. Producers.......All Producers - Small U.S........Total.....................% Impact 9L Cases........................................500,000....................... 176,500,000........... 177,000,000 Proof Gallons (@80P).......................952,381....................... 336,190,476........... 337,142,857 Current FET......$13.5 for all...........$12,857,143................. $4,538,571,429 ........ $4,551,428,571 Proposed FET...$2.70 & $13.50...... $2,571,429..................$4,538,571,429..........$4,541,142,857 Tax Impact.................................- $10,285,714.....................................$0............- $10,285,714..............-0.23% If these numbers are close to correct, then the potential loss of excise tax revenue for creating a lower tier for small producers would be minimal. We need to come up with a good approximation of the flip side of this equation for the benefits we generate for the U.S. economy (as most of our products compete with imports). I don't image it would be difficult to prove that the 150+ of us add up to more than $10 mil tax loss in the context of local employment and employment taxes, purchase of local goods and services, and, in some states, tourism. Please weigh in on the above numbers and anything you could add to the benefits analysis. At this point, I'd like to invite Paul McCann of Parched Group LLC, a fellow maker who was once a gov't policy analyst, to help us put this in a format that would make the most sense to elected officials. I think we're pretty close to ready to present this to our elected officials. Thanks all for your support. Get ready to talk to your congressman or woman! NEXT STEPS: - Get support level to 50 producers (DONE) - Get statistics and perform analysis (DOING) - Frame tight argument with supporting points and analysis (DOING) - Start talking to elected officials and ID 1-2 who are willing to sponsor bill later this year or Jan. (NEED TO DO)

We've got 59 so far who've signed on through this board or I've spoken with by phone (in parentheses). We've crossed the critical mass of 50! Current Producers 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 2. Colorado Gold LLC, Cedaredge, CO 3. Tuthilltown Spirits, Gardiner, NY 4. Dry Fly Distilling, Spokane, WA 5. Ellensburg Distillery LLC Ellensburg, WA 6. Dynamic Alambic Artisan Distillers LLC Mattawa, WA 7. Great Lakes Distillery LLC, Milwaukee, WI 8. Drum Circle Distilling, Sarasota, FL 9. Grand Traverse Distillery, Traverse City, MI 10. Mystic Mountain Distillery, Larkspur, CO 11. Pacific Distillery LLC, Woodinville, WA 12. Delaware Phoenix Distillery, Walton, NY 13. Heartland Distillers, Fishers, IN 14. Fat Dog Spirits, Tampa, FL 15. Harvest Spirits LLC, Valatie, NY 16. Cascade Peak Spirits, Ashland, OR 17. New Holland Brewing Co. and Artisan Spirits, Holland, MI 18. Newport Distilling Company, Newport, RI 19. 45th Parallel Spirits LLC. New Richmond, WI 20. Gnostalgic Spirits, Ltd., Portland, OR 21. Blackwater Distilling Inc., Annapolis, MD 22. Cold Smoke Distillery Inc., Bozeman, MT 23. The Solas Distillery, Omaha, NE 24. Parched Group LLC, Richmond, VA 25. AEppelTreow Winery, Burlington, WI 26. Leopold Bros. Small Batch Distillers, Denver, CO 27. The American Distilling Institute 28. The Brewers of Indiana Guild 29. Sweetgrass Farm Winery & Distillery, Union, ME 30. Downslope Distilling Inc., Littleton, CO 31. North Shore Distillery LLC, Lake Bluff, IL 32. Finger Lakes Distilling LLC, Burdett, NY 33. St. George Spirits Inc., Alameda, CA (34. Philadelphia Distilling, Philadenlphia, PA) (35. Distillery 209, San Francisco, CA) (36. Peak Spirits, Hotchkiss, CO) (37. Maine Distilleries, Freeport, ME) (38. Clear Creek Distillery, Portland, OR) 39. Ryan & Wood Inc, Gloucester, MA 40. Artisan Spirits, Portland, OR 41. Bendistillery, Bend, OR 42. Brandy Peak Distillery, Brookings, Oregon 43. Dolmen Distillery, McMinnville, Oregon 44. Highball Distillery, Portland, OR 45. House Spirits, Portland, Oregon 46. Indio Spirits, Tigard, Oregon 47. Integrity Spirits, Portland, Oregon 48. Northwest Distillery Inc, Warren, OR 49. McMenamins Edgefield Distillery, Troutdale, OR 50. New Deal Distillery, Portland, OR 51. Ransom Distillery, McMinnville, OR 52. Rogue Spirits, Portland, Oregon 53. Sub Rosa Spirits, Portland, Oregon 54. Integrity Spirits, Portland, OR Producers In Licensing Process 1. Sherman in KY 2. Paul in CA 3. Penobscot Bay Distillery, Winterport, ME 4. Las Vegas Distillery LLC, Las Vegas, NV 5. River Town Distillers LLC, Snohomish, WA

UPDATE: As we develop our proposal and gather support, I've reached out to the TTB to make sure they're aware of our interest in creating a lower FET rate and are involved in crafting proposed legislation that not only meets our needs but is simple for all (us and the TTB) to implement. A few important takeaways from my conversation: - Our interest in creating a lower tier FET rate was not a shocker to the TTB - $2.70/PG seemed low to them (have to make sure this is within same parameters as beer/wine and reflects challenges we have in common with them and some that are unique to spirits producers) - Pool of eligible producers must be limited - Implementation should be straightforward Our TTB contact agreed to put us in touch with a dept. liaison who would work with us in developing a workable proposal. They would also provide us with statistics on who pays what so can develop our proposal and analysis in context and within reason. Need to wrap this up quickly so we can all start talking with our elected officials and before we all get too buried in production/selling. NEXT STEPS: - Get support level to 50 producers - Get statistics and perform analysis - Frame tight argument with supporting points and analysis - Start talking to elected officials and ID 1-2 who are willing to sponsor bill later this year or Jan.

Agree completely. Had converted #s to PGs a few pages ago: Reduced excise tax rates apply to the first 150,000 proof gallons of spirits if producers make no more than 250,000 proof gallons per year.

Thanks for everyone who's voiced support! We've got 43 so far who've signed on through this board or I've spoken with by phone (in parentheses). Almost at critical mass of 50! Current Producers 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 2. Colorado Gold LLC, Cedaredge, CO 3. Tuthilltown Spirits, Gardiner, NY 4. Dry Fly Distilling, Spokane, WA 5. Ellensburg Distillery LLC Ellensburg, WA 6. Dynamic Alambic Artisan Distillers LLC Mattawa, WA 7. Great Lakes Distillery LLC, Milwaukee, WI 8. Drum Circle Distilling, Sarasota, FL 9. Grand Traverse Distillery, Traverse City, MI 10. Mystic Mountain Distillery, Larkspur, CO 11. Pacific Distillery LLC, Woodinville, WA 12. Delaware Phoenix Distillery, Walton, NY 13. Heartland Distillers, Fishers, IN 14. Fat Dog Spirits, Tampa, FL 15. Harvest Spirits LLC, Valatie, NY 16. Cascade Peak Spirits, Ashland, OR 17. New Holland Brewing Co. and Artisan Spirits, Holland, MI 18. Newport Distilling Company, Newport, RI 19. 45th Parallel Spirits LLC. New Richmond, WI 20. Gnostalgic Spirits, Ltd., Portland, OR 21. Blackwater Distilling Inc., Annapolis, MD 22. Cold Smoke Distillery Inc., Bozeman, MT 23. The Solas Distillery, Omaha, NE 24. Parched Group LLC, Richmond, VA 25. AEppelTreow Winery, Burlington, WI 26. Leopold Bros. Small Batch Distillers, Denver, CO 27. The American Distilling Institute 28. The Brewers of Indiana Guild 29. Sweetgrass Farm Winery & Distillery, Union, ME 30. Downslope Distilling Inc., Littleton, CO 31. North Shore Distillery LLC, Lake Bluff, IL 32. Finger Lakes Distilling LLC, Burdett, NY 33. St. George Spirits Inc., Alameda, CA (34. Philadelphia Distilling, Philadenlphia, PA) (35. Distillery 209, San Francisco, CA) (36. Peak Spirits, Hotchkiss, CO) (37. Maine Distilleries, Freeport, ME) (38. Clear Creek Distillery, Portland, OR) 39. Ryan & Wood Inc, Gloucester, MA Producers In Licensing Process 1. Sherman in KY 2. Paul in CA 3. Penobscot Bay Distillery, Winterport, ME 4. Las Vegas Distillery LLC, Las Vegas, NV

We're shooting for 150,000 PG out of a max 250,000 PG of production/yr that would qualify for the lower tax tier. Not sure where you got the 10,000 PG, which would be too small. Please spread the word to the other OR makers to come online and support this initiative.

Thanks for everyone who's voiced support! We've got 34 so far. Still missing many... Current Producers 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 2. Colorado Gold LLC, Cedaredge, CO 3. Tuthilltown Spirits, Gardiner, NY 4. Dry Fly Distilling, Spokane, WA 5. Ellensburg Distillery LLC Ellensburg, WA 6. Dynamic Alambic Artisan Distillers LLC Mattawa, WA 7. Great Lakes Distillery LLC, Milwaukee, WI 8. Drum Circle Distilling, Sarasota, FL 9. Grand Traverse Distillery, Traverse City, MI 10. Mystic Mountain Distillery, Larkspur, CO 11. Pacific Distillery LLC, Woodinville, WA 12. Delaware Phoenix Distillery, Walton, NY 13. Heartland Distillers, Fishers, IN 14. Fat Dog Spirits, Tampa, FL 15. Harvest Spirits LLC, Valatie, NY 16. Cascade Peak Spirits, Ashland, OR 17. New Holland Brewing Co. and Artisan Spirits, Holland, MI 18. Newport Distilling Company, Newport, RI 19. 45th Parallel Spirits LLC. New Richmond, WI 20. Gnostalgic Spirits, Ltd., Portland, OR 21. Blackwater Distilling Inc., Annapolis, MD 22. Cold Smoke Distillery Inc., Bozeman, MT 23. The Solas Distillery, Omaha, NE 24. Parched Group LLC, Richmond, VA 25. AEppelTreow Winery, Burlington, WI 26. Leopold Bros. Small Batch Distillers, Denver, CO 27. The American Distilling Institute 28. The Brewers of Indiana Guild 29. Sweetgrass Farm Winery & Distillery, Union, ME 30. Downslope Distilling Inc., Littleton, CO 31. North Shore Distillery LLC, Lake Bluff, IL Producers In Licensing Process 1. Sherman in KY 2. Paul in CA 3. Penobscot Bay Distillery, Winterport, ME

This nails it on the head! We're trying to create a level playing field for small, innovative producers. How they produce -- while relevant in other contexts -- is secondary for this effort. This is a very interesting chart. What's the source? This type of data will be useful in making our case. Could you share the raw data?

Thanks for your support, Todd. Your point is absolutely valid, but in a different context. For our efforts to create a lower excise tier, we need to keep things broad and simple to even have a chance to get a bill proposed.

This proposed tax tier is for all craft spirits makers, not just distillers. That's why we need to define the category more broadly with the emphasis on craft vs tools. Those who don't have stills have sometimes invested as much or more in blending and aging containers, barrels, filtration equipment, bottling lines, etc. -- nearly identical capital costs with similarly low economies of scale as operations that use stills. Plus, there are no labor savings when you hand zest a thousand pounds of lemons, slice and scape hundreds of pounds of vanilla beans or cut hundreds of pounds of green walnuts by hand. All small craft makers should benefit from a lower tax tier because we're all similarly hindered in pricing power and operational efficiency compared to large producers.

Think we might just need to separate this definition: - One for our lobbying efforts, which will need to be simple and easy to implement (continue on lobbying thread) - Another for marketing and self-identification, which can touch on all the issues of quality, place and craft that matter to us on multiple levels

NEXT STAGE: Defining the Bill's Scope Now that we have the ball rolling, let's open up the guts of our proposal and talk through the two key pieces that legislators will need to be nailed down to turn our idea into reality: - Which producers qualify for reduced excise rates - How much production qualifies for the lower rate As a general observation, we need to keep a couple of process and context issues in mind: - Complicated legislation takes a long time and lots of money to pass --> we should keep this simple and easy to implement - We're in a recession --> we should limit our proposal's scope because lawmakers will kill it if the loss of excise revenue is too high 1. Type of Producer Ralph Erenzo of Tuthilltown Spirits, who started the thread on defining craft producers, recently posted the upshot of six months of discussion on this topic, which I'd propose as a jumping off point for us: Craft spirits makers produce beverage spirits primarily from agricultural raw materials. A Craft Spirits Producer utilizes a variety of technical skills in the preparation which substantially changes the character of the original material, including but not limited to: infusion, batch distillation and/or redistillation. 2. Size of Production at Lower Rate Brent Ryan of Newport Distilling Company made a keen observation that when the brewers were going through this very exercise they set 15,000 bbls as their utmost limit because they never imagined going beyond it. "Brewers like Boston Beer (~1,300,000 bbls now) and Sierra Nevada (~700,000 bbls now)," Ryan writes, "were part of these very discussions." We may get one chance to set a lower bar -- let's not shoot ourselves in the foot by aiming too low. Reduced excise tax rates apply to the first 150,000 proof gallons of spirits if producers make no more than 250,000 proof gallons per year. Please weigh in on the substance of these two issues. Some specific questions that come to my mind: - Should blenders be included in the producer class? John Glaser of Compass Box comes to mind. He buys and blends whiskies to create incredible vatted malts. - Subcontract produced brands (dba's) -- should this type of production qualify? Lots of small brands fit this profile but the actual producers tend to be large outfits. - What about column distillers? Lastly, I'd like to thank Paul McCann of Parched Group, LLC, a former government policy analyst, who's volunteered to perform a simple financial analysis of this proposal to show how much revenue loss reduced excise rates may generate vs positive impact of more U.S. job creation (as most of our products compete with imports, not domestic brands).

Thanks for everyone who's voiced support! We've got 27 so far. Still missing many... Current Producers 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 2. Colorado Gold LLC, Cedaredge, CO 3. Tuthilltown Spirits, Gardiner, NY 4. Dry Fly Distilling, Spokane, WA 5. Ellensburg Distillery LLC Ellensburg, WA 6. Dynamic Alambic Artisan Distillers LLC Mattawa, WA 7. Great Lakes Distillery LLC, Milwaukee, WI 8. Drum Circle Distilling, Sarasota, FL 9. Grand Traverse Distillery, Traverse City, MI 10. Mystic Mountain Distillery, Larkspur, CO 11. Pacific Distillery LLC, Woodinville, WA 12. Delaware Phoenix Distillery, Walton, NY 13. Heartland Distillers, Fishers, IN 14. Fat Dog Spirits, Tampa, FL 15. Harvest Spirits LLC, Valatie, NY 16. Cascade Peak Spirits, Ashland, OR 17. New Holland Brewing Co. and Artisan Spirits, Holland, MI 18. Newport Distilling Company, Newport, RI 19. 45th Parallel Spirits LLC. New Richmond, WI 20. Gnostalgic Spirits, Ltd., Portland, OR 21. Penobscot Bay Distillery, Winterport, ME 22. Blackwater Distilling Inc., Annapolis, MD 23. Cold Smoke Distillery Inc., Bozeman, MT 24. The Solas Distillery, Omaha, NE 25. Parched Group LLC, Richmond, VA Producers In Licensing Process 1. Sherman in KY 2. Paul in CA

Fully support Ralph's revised definition -- emphasizing "craft producer" over tools. This is an important piece of the lobbying work we have ahead of us to lower excise taxes.

Thanks for everyone who's voiced support! We're up to 20 so far... Current Producers 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 2. Colorado Gold LLC, Cedaredge, CO 3. Tuthilltown Spirits, Gardiner, NY 4. Dry Fly Distilling, Spokane, WA 5. Ellensburg Distillery LLC Ellensburg, WA 6. Dynamic Alambic Artisan Distillers LLC Mattawa, WA 7. Great Lakes Distillery LLC, Milwaukee, WI 8. Drum Circle Distilling, Sarasota, FL 9. Grand Traverse Distillery, Traverse City, MI 10. Mystic Mountain Distillery, Larkspur, CO 11. Pacific Distillery LLC, Woodinville, WA 12. Delaware Phoenix Distillery, Walton, NY 13. Heartland Distillers, Fishers, IN 14. Fat Dog Spirits, Tampa, FL 15. Harvest Spirits LLC, Valatie, NY 16. Cascade Peak Spirits, Ashland, OR 17. New Holland Brewing Co. and Artisan Spirits, Holland, MI 18. Newport Distilling Company, Newport, RI Producers In Licensing Process 1. Sherman in KY 2. Paul in CA Next steps: - Build list to 50 supporters -- could everyone contact 2-3 other makers and get them to sign on by this Friday? I'll take care of CA and IL. - Finalize proposal - Contact our reps (and probably make a small donation to their re-election funds)

Thanks for everyone who's voiced support! We've got 10 so far... 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 2. Colorado Gold LLC, Cedaredge, CO 3. Tuthilltown Spirits, Gardiner, NY 4. Dry Fly Distilling, Spokane, WA 5. Ellensburg Distillery LLC Ellensburg, WA 6. Dynamic Alambic Artisan Distillers LLC Mattawa, WA 7. Great Lakes Distillery LLC, Milwaukee, WI 8. Drum Circle Distilling, Sarasota, FL 9. Grand Traverse Distillery, Traverse City, MI 10. Mystic Mountain Distillery, Larkspur, CO Next steps: - Build list to 50 supporters -- could everyone contact 5 other makers and get them to sign on by this Friday? I'll take care of CA and IL. - Finalize proposal - Contact our reps (and probably make a small donation to their re-election funds)

We may need additional information in our back pockets to persuade some legislators, but I think we're better off with a "short & sweet" upfront approach where we're simply attempting to level the playing field. One thing that would help, though, is getting as many of our peers as possible to sign on. Please forward to as many producers that fit the profile as you know.

As a follow up to the discussion from the DEFINING "CRAFT" DISTILLERY thread, here's a one-page position document for all of us to discuss, finalize, gather support for from fellow spirits makers and take to our federal legislators ASAP to create a new, lower federal excise tax tier for small-scale spirits maker. The structure below closely follows the TTB's existing format. As I only had a short window to put this together, please double-check all facts and figures before we take this to broader audiences. ______________________________________________________________________ Small Spirits Makers' Equal Tax Act Goal Encourage the growth of hand-crafted spirits production in the U.S. by creating a reduced federal excise tax rate for small-scale distilled spirits makers, similar to the current reduced tiers for beer and wine producers. Background The distilled spirits industry has enjoyed a renaissance of local, artisan production of unique spirits over the last five years. Our numbers have swelled from less than 40 licensed makers in 2003 to more than 150 in 2008. Because of our efforts, U.S. and even some overseas consumers are beginning to experience innovation and quality in spirits products they can find in the marketplace that mirror what beer lovers enjoyed with the birth of micro-brewers in the 1980s-1990s and wine lovers with the emergence of the independent winemakers in the 1970s-1980s. What made the growth of small beer and wine makers possible -- other than hard work and passion -- was a reduced federal excise tax rate that allowed them to compete with much larger producers who benefited from the economies of large-scale production. Today, small-scale beer producers pay 39% of the $18 per barrel in federal excise tax for the first 60,000 barrels they make if they produce less than 2 million barrels per year. Similarly, small producers of average-proof wine (<14% alcohol) pay 18% of the $1.07 per gallon in federal excise tax for the first 100,000 gallons they remove provided they make no more than 150,000 gallons per year. To put this in context, small beer producers pay $0.02 vs $0.05 in federal excise tax per 12 oz can, while small wine producers pay $0.04 vs $0.21 per 750 ml bottle. By contrast, spirits makers -- large or small -- pay the same $13.50 per proof gallon or $2.14 per 80-proof 750 ml bottle of spirits. Proposal Small-scale spirits producers need a similar reduced-rate federal excise tax structure to continue to innovate and compete effectively with large-scale producers. We the undersigned producers propose the following structure to bring balance to small distilled spirits producers that mirrors the excise rates of small beer and wine producers: Tier one/regular -- 100% rate, Tier two/small-scale -- 20% rate. Proposed Distilled Spirits Excise Tax Rates Distilled Spirits.............Proof Gallons*.............750ml Bottle Regular Rate................$13.50.......................$2.14 (at 80 proof) Reduced Rate**............$2.70.........................$0.43 (at 80 proof) * A proof gallon is a gallon of liquid that is 100 proof, or 50% alcohol. The tax is adjusted, depending on the percentage of alcohol of the product. ** Reduced Rate -- For the first 60,000 gallons of spirits if producers make no more than 100,000 gallons per year. Producers who support this legislation 1. Modern Spirits LLC 168 W Pomona Ave, Monrovia, CA 91016

Ralph, I agree that we need to take this conversation to another level and act, particularly as the window before elections -- when we could make some impact -- will be closing soon. I'm working on a short position paper on lowering the federal excise tax rate for small producers -- something all of us can agree on. If anyone has data that could help make our case, please email them to me at melkon@modernspiritsgroup.com. I'll post it over the weekend on a new threat so we can hash out some specifics: target excise rate, maximum production volumes, etc.

How about calling the umbrella group the American Artisan Spirits Guild (AASG) or the American Craft Spirits Guild (ACSG), which can have many subgroups even at its inception? But we lobby as a group for things that matter to all of us. Qualifications: - DSP license - Making less than 60K PGs Ultimately, those who make BS products will come out in the wash or need to up their game, which will strengthen our category. What do you all think?

This is pretty much where we Calif. liquor makers were two years ago in organizing our efforts when all collaboration fell apart -- who's in, who's out, who distills, who re-distills, who rectifies, who starts with mash, who starts with ngs, who farms their own ingredients. There is no good at the end of this puritanism. A better question should be -- who makes spirits that reflect quality, place and point of view? Tools and techniques should come second to maker and know how. All these finer shades of gray issues -- which I agree are legitimate -- will hijack our group effort if we focus on them now. Why not pool the efforts of all small DSPs to lobby for some basic needs that touch us all? We can certainly come back in a few years to define products by the types of tools different artisan groups use to make their spirits.