DEFINING "CRAFT" DISTILLERY

[Penn]

All,

The semantic issues are important (whisky v. whiskey and what the distinction might mean). But in my mind the definition of craft distiller takes priority. We need a consensus on the definition in order to present it as "Craft Distilling as Defined by the American Distilling Institute." We need to do this in order to establish a reference point that legal people, legislators, lobbyists, and producers can use to acquire standing. Without a definition, the craft distiller becomes subject to whimsical, arbitrary, and occasionally malicious legislative decisions regarding permits, taxation, and regulation.

The key element in Ralph's proposed definition is the ceiling on proof gallons. 50,000 may seem high, but I don't think it is.

If we follow the brewers, micro means less than 15,000 barrels, regional means less than 50,000 barrels, and craft means less than 1,000,000 barrels. Hence, Boston Brewing is still considered a craft brewer, but just barely. (A barrel is 31 gallons).

We also agree that distillers must distill.

Are there serious reservations about the definition as written? If so, we'd like to hear them. If not, we intent to publish the definition in the upcoming issue of DISTILLER, and post it on the website as a permanent statement.

Thoughts?

[Penn]

All,

The semantic issues are important (whisky v. whiskey and what the distinction might mean). But in my mind the definition of craft distiller takes priority. We need a consensus on the definition in order to present it as "Craft Distilling as Defined by the American Distilling Institute." We need to do this in order to establish a reference point that legal people, legislators, lobbyists, and producers can use to acquire standing. Without a definition, the craft distiller becomes subject to whimsical, arbitrary, and occasionally malicious legislative decisions regarding permits, taxation, and regulation.

The key element in Ralph's proposed definition is the ceiling on proof gallons. 50,000 may seem high, but I don't think it is.

If we follow the brewers, micro means less than 15,000 barrels, regional means less than 50,000 barrels, and craft means less than 1,000,000 barrels. Hence, Boston Brewing is still considered a craft brewer, but just barely. (A barrel is 31 gallons).

We also agree that distillers must distill.

Are there serious reservations about the definition as written? If so, we'd like to hear them. If not, we intent to publish the definition in the upcoming issue of DISTILLER, and post it on the website as a permanent statement.

Thoughts?

[cowdery]

Defining craft distilling is a worthy enterprise. My point is a small one. There is no legal distinction, anywhere, between whiskey and whisky. They are merely two different spellings of the same word, like color and colour. Some people don't seem to get this, or don't believe it, but it is the case nonetheless.

There are also differences between the official U.S. definition of whiskey and the official EU definition of whiskey, but they have nothing to do with how the word is spelled.

I bring this up only so that people don't get sidetracked by a non-issue. Everything else in Ralph's post is correct and relevant.

[Ralph at Tuthilltown]

It is true that there is no precedent to argue the difference between "whiskey" and "whisky". However, the fact is there are distinct differences between what the Scotch Whisky Association and the EU consider to be "whisky" or "whiskey" and what the US Federal Government, and thereby American distillers may characterize as "whiskey".

The EU has chosen to specifically include "American bourbon and rye" whiskeys in the EU definition of the "whisky/whiskey" class. If we do not define what "whiskey" is, the EU will define it for us. It means under that definition there can be no "Corn Whiskey". There can be no experimental short aged whiskeys.

More to the point, there is a distinct difference between Euro-Whisky and American Whiskey; it's the quality and character of the oak required. It has a profound effect on the spirit and separates the two types of whiskey/whiskys one from the other.

One can argue that it's not "necessary" to define whiskey or whisky, or craft distiller, or artisan distiller. But the simple fact of the matter is that if we do not define our own industry and our products in terms we accept as a community, others will do it for us, like the Federal regulators, or the EU protectionists.

[cowdery]

if we do not define our own industry and our products in terms we accept as a community, others will do it for us, like the Federal regulators, or the EU protectionists.

Isn't that horse already out of the barn?

While the goal of agreeing on terms as an industry is laudable, debating the meaning of terms whose definitions already are part of U.S. and EU law seems like a waste of time or, at least, a very different enterprise. Perhaps your use of the term "protectionist" to characterize the EU's rules tells us something about your point-of-view.

All rugged individualism aside, there are rules and some of them can have absurd results. I believe it is you, Ralph, who have pointed out that New York's law permitting craft distilling is premised on the use of local farm products, which makes it difficult to make rye whiskey since New York doesn't grow much rye. Phil Prichard has said that he would like to make rum from sorghum, a traditional source of sweetener in the South, but the federal regs unhelpfully limit the term rum to sugar cane products. If you want to challenge existing state, federal or international regulations that is, as I said, a very different enterprise than the one envisioned at the beginning of this thread.

The U.S. and EU regs are different with regard to the definition of whiskey. Since the U.S. definition is simply more inclusive, anything that can be sold as whiskey in the EU is whiskey here too, but not the other way around. In the EU, you can't call your product whiskey unless it has spent at least three years in wood. One effect of this has been that Seagram's Seven Crown American Blended Whiskey had to be reformulated for sale in Europe.

With corn whiskey, US regs allow unaged corn whiskey, EU regs do not. Unaged corn whiskey may be sold in Europe as "corn spirit," or under some other name, it just cannot be called whiskey.

On the subject of wood, the roles are reversed, with the EU being more inclusive. The EU makes no distinction between used and new, charred or uncharred, whereas the U.S. requires that certain types of whiskey (bourbon, rye, etc.) must be aged in new, charred barrels, while other types (corn) must be aged in used or uncharred cooperage. This does not, however, mean that in Europe you can sell as bourbon something aged in used barrels. By treaty, the EU has basically agreed to accept the U.S. definition of bourbon.

Learning the regs and formulating your products accordingly would seem to me, as an observer, to be the best practice.

As for the spelling, nowhere in the world is there any rule that applies to whiskey that does not apply in exactly the same way to whisky and vice versa, therefore spelling is irrelevant.

[Ralph at Tuthilltown]

This is from the Scotch Whisky Association website:

Most well-known dictionaries give both spellings. The Oxford English Dictionary points out that 'in modern trade usage, Scotch Whisky and Irish Whiskey are thus distinguished in spelling'. American-made whiskey is usually spelt with an 'e', while Canadian and Japanese whisky are not.

Seems safe to assume that the SWA would not post the reference if it did not agree. Further exploration of the SWA site reveals not one single use of the American spelling of Whiskey in any defining way, nor does it mention American Bourbon and American Rye whiskeys, all the references to the definition contained on the SWA site are for, specifically "Scotch Whisky".

It is not true to say that no rule applies to "whisky" which does not apply equally to "whiskey", the fact the SWA uses "whisky" to describe Scotch, and must specifically add "American Whiskey" as also included in the definition clearly implies the difference. There are absolute differences between the Scotch and American whiskey. Those differences are called out by the SWA. But they can't have it both ways.

And it seems only right (though naive to believe it would happen) that since Scotch does not meet our definition of "whiskey" the prohibition should be recripocal given the EU ruling and Scotch Whisky producers should relabel, eliminating the word "whisky" from the labels of all they ship to the US. What's good for the goose........

[grehorst]

I like Ralph's definition, but I think the last sentence should be dropped. I think when defining who you are you should not cloud the issue by trying to define who you aren't.

I think this says enough...

"Craft distillers produce alcoholic beverage spirits by distillation, or by infusion through distillation or redistillation. Maximum production for a "craft" or "artisan" distiller should not exceed 50,000 proof gallons per year. The "craft" or "artisan" distiller utilizes a pot still, with or without rectification columns, for distillation of beverage spirits".

thoughts??

[Ralph at Tuthilltown]

Perhaps the nature of the stills is the key to the definition. A craft distiller uses pot stills. Could the size and type of still be the determining factor? A 1200 gallon still is not producing the same way as a 200 gallon still. Maybe....... Food for thought. Any comments?

[Ralph at Tuthilltown]

I think Guy is correct. That last line should be dropped. Any discussion of what is "not" a craft/artisan/micro distiller should be for attachment in some kind of "caselaw" type document clarifying the ADI position. I do think it important to separate out those who actually produce their goods from those who just rebottle or distill simple vodka from GNS, or buy their spirits from others and bottle it under their label.

[grehorst]

Perhaps the nature of the stills is the key to the definition. A craft distiller uses pot stills. Could the size and type of still be the determining factor? A 1200 gallon still is not producing the same way as a 200 gallon still. Maybe....... Food for thought. Any comments?

Not to bring up any tasteless metaphors but, I don't think it's the size of the still that matters but how you use it . I think use of a potstill and the definitions max gallonage (50,000) is a great category definition in itself.

[delaware_phoenix]

I don't think many consumers have much of an idea about how spirits are made. They think everyone does what you describe. Taking GNS, adding flavorings, and being able to call that whiskey (regardless of spelling) is not something the consumer understands.

Quality beverages don't need Coke® added to them.

[Melkon Khosrovian]

Ralph,

Thanks for reviving this important issue. As some of you know (hi Charles), defining "craft" has come up and gone away unresolved many times. Agreeing on the scope and size of "craft" is going to be critical to passing many pieces of local and national legislation that will help small producers thrive. Though I think that we'll need a more formal setting to hammer out a draft definition, here are my few thoughts on what's types of producers should be called "craft."

1. Open it up to every DSP of a certain size -- distillers and rectifiers. Why? Because stills aren't needed for making a whole range of handcrafted products. We at Modern Spirits make two portfolios of infused vodkas that are impossible to replicate through re-distillation. Our friend, George Monteverdi, in Napa, makes a celebrated Nocino without a still. To many consumers, these limited run, hand-produced spirits that reflect locality, a point of view and high quality are dictionary definitions of craft. Limiting the field to distillers (and then only to those who use pot stills) ultimately doesn't help consumers in their search for quality and authenticity from "craft" products.

2. Require that makers actually make the product -- e.g., no sub-contractor produced finished products. Why? Because it's about individual style and passion. And DBA brands don't bring this to the table.

3. Establish minimum quality standards for craft producers -- e.g., commitment to quality, local (when possible) ingredients, no additives designed to mask poor quality and ongoing education. Consumers expect the best of this class of product and we have to be able to deliver it. The fastest way to kill our chances to succeed as a movement is to deliver sub-par products to the marketplace...even with a pot still.

4. Set production limits that make sense now and a few years from now. If we set up #2 + 3 correctly, then we can grow without compromising quality or our integrity for a long time.

In the end, it's about creating a stellar handcrafted product for the customer and having a level playing field in which to compete against industrial producers. I suspect that distinctions between in-house base spirits vs GNS and column vs pot still mean as much to customers as chefs arguing about what's the best type of pan for a dish. Ultimately, they just want a tasty, thoughtfully prepared meal!

Melkon

[cowdery]

Open it up to every DSP of a certain size -- distillers and rectifiers.

A good suggestion, well supported, that is more inclusive than a distiller's-only club, and it's based on more relevant criteria, but it affects what you can call the category. You can't let non-distillers into a classification called "craft distillers," but one can make a very good case for calling the classification "craft distillers and rectifiers" or "craft distilled spirits producers" (my preference). The empahsis should be on "craft," what makes a product or operation "craft"? Can we agree that there are distilled spirits producers who make finely crafted distilled spirits products without running a still? If so, then the group is better with them a part of it.

I would endorse a rule that you can't call yourself a distiller if you're not, but that would be a non-starter. Too many of the big guys do it.

This proposal also resolves the matter of producers whose products contain both their own and third-party distillate, and eliminates without addressing it directly the question of pot stills only, since the criteria would be the craft production of any distilled spirits product at under a certain production volume, regardless of still use or type.

[Melkon Khosrovian]

I like "Craft Distilled Spirits Producers" too -- or even shorter, "Craft Spirits Producers."

Makes it simple and easy to define, as well:

* Craft -- size

* Spirits -- distilled spirits of all types

* Producers -- maker made (vs subcontractor brands)

[Jonathan Forester]

I'm a bit late coming back to the revival of this discussion, although I have kept an eye on it over the past few months. I really think this is a critical discussion and decision on the part of artisanal distillers. We have to decide who we are, and are not. Or else other will soon decide this for us, to our detriment.

There are some important points that have come up.

Melkon- If we go by part 1 of your definition, there has to be some way to delineate who are distilling their entire product, those who are rectifying spirits by adding artisanal value through infusing and/or re-distillation with botanicals, vs. the supposed craft distillers which just buy spirits, add water, and rectify/re-distill and call it a craft or artisanal product without adding anything positive or discernible to it.

I heartily agree with number 2, 3, and 4.

I also feel that dba's who buy bulk and bottle, or contract to have product bottled, need to be in a separate category, and not artisanal/craft distilling.

Ralph said this quite well, "Craft distillers produce alcoholic beverage spirits by distillation, or by infusion through distillation or redistillation. Maximum production for a "craft" or "artisan" distiller should not exceed 50,000 proof gallons per year. The "craft" or "artisan" distiller utilizes a pot still, with or without rectifcation columns, for distillation of beverage spirits. A distiller starting with neutral spirits produced by others, who redistills without substantially altering the neutral character of the spirit may not be said to be a "craft" or "artisan" distiller."

***

"This definition deliberately excludes producers of infused products making use of alcohol which the producer has not made from the fermentation and/or distillation process. It is inclusive of the distiller who starts with grain neutral spirits and then redistills as a function of infusion or some other process which substantially alters the neutral character of the original spirit. It excludes the distiller who starts with gns and merely runs it through a still again to create another neutral spirit; or starting with grain neutral spirits only adds flavoring and/or color unless those changes are introduced as the result of distillation, not merely as additives. It excludes blenders or bottlers who buy spirits from another distiller to blend and bottle it under another brand. The "distiller" must distill."

Does there need to be sub-categories within the artisanal distilling definition? Some small distilleries are producing minute amounts of product, while others are producing much more. Setting a limit of 50,000 gallons is a good start, but... what about those who produce much less? Should they get there own category, with the possibility of more federal and state economic help and incentives?

We also need to clear the air around the actual definition of the plethora of terms being bandied about: artisanal distilled, craft-distilled/ing, hand-distilled, micro-distilled, micro-batch, nano-batch, nano-distilled, etc.

As I mentioned near the beginning of this thread, but no one responded too, what about Ansley Coale at Hangar One and their trade mark of the term "Craft Distillers?" What impact, or importance, if any, does this have?

Ralph,

Thanks for reviving this important issue. As some of you know (hi Charles), defining "craft" has come up and gone away unresolved many times. Agreeing on the scope and size of "craft" is going to be critical to passing many pieces of local and national legislation that will help small producers thrive. Though I think that we'll need a more formal setting to hammer out a draft definition, here are my few thoughts on what's types of producers should be called "craft."

1. Open it up to every DSP of a certain size -- distillers and rectifiers. Why? Because stills aren't needed for making a whole range of handcrafted products. We at Modern Spirits make two portfolios of infused vodkas that are impossible to replicate through re-distillation. Our friend, George Monteverdi, in Napa, makes a celebrated Nocino without a still. To many consumers, these limited run, hand-produced spirits that reflect locality, a point of view and high quality are dictionary definitions of craft. Limiting the field to distillers (and then only to those who use pot stills) ultimately doesn't help consumers in their search for quality and authenticity from "craft" products.

2. Require that makers actually make the product -- e.g., no sub-contractor produced finished products. Why? Because it's about individual style and passion. And DBA brands don't bring this to the table.

3. Establish minimum quality standards for craft producers -- e.g., commitment to quality, local (when possible) ingredients, no additives designed to mask poor quality and ongoing education. Consumers expect the best of this class of product and we have to be able to deliver it. The fastest way to kill our chances to succeed as a movement is to deliver sub-par products to the marketplace...even with a pot still.

4. Set production limits that make sense now and a few years from now. If we set up #2 + 3 correctly, then we can grow without compromising quality or our integrity for a long time.

In the end, it's about creating a stellar handcrafted product for the customer and having a level playing field in which to compete against industrial producers. I suspect that distinctions between in-house base spirits vs GNS and column vs pot still mean as much to customers as chefs arguing about what's the best type of pan for a dish. Ultimately, they just want a tasty, thoughtfully prepared meal!

Melkon

[Guest sensei]

As I mentioned near the beginning of this thread, but no one responded too, what about Ansley Coale at Hangar One and their trade mark of the term "Craft Distillers?" What impact, or importance, if any, does this have?

Is it not possible to show that this term is not and cannot be unique to one particular distillery? It seems silly that they would even apply for such IP protection. Its like harley telling Victory that they cannot call themselves "American Motorcycles" because H-D was there first.

[Sonja]

Is it not possible to show that this term is not and cannot be unique to one particular distillery? It seems silly that they would even apply for such IP protection. Its like harley telling Victory that they cannot call themselves "American Motorcycles" because H-D was there first.

I don't disagree, but it'll be interesting to see how this issue plays out, as those folks are using the name "Craft Distillers" to market their portfolio of products now - someone was introduced to me as being "from Craft Distillers" last week (who was, in actuality, a rep from the distributor for them here in Chi-town). Not sure if/when the issue will come to a head, but I imagine it will at some point!

[cowdery]

While there may be some impediment to another distillery using "Craft Distillers" as all or part of its name, there is absolutely no legal impediment to the use of "craft distiller," "craft distillery," or any variation thereof as descriptive terms. Anyone who states something to the contrary is either ignorant of the relevant laws or being deliberately misleading. This concern may be safely put to rest.

While the standards being discussed here wouldn't necessarily have the weight of law, what you can do as a trade organization is condition membership on acceptance of and adherence to ADI standards.

I continue to hold that restricting "craft" to users of pot stills is short-sighted, misguided and, if you permit those pot stills to have rectification columns, meaningless.

[delaware_phoenix]

If one looks at the historical development of the rectifying devices in early 19th century France, one sees all sorts of devices (balls, cylinders with plates, ie columns, etc) being attached to the output of a pot still in order to increase the alcoholic gravity of a run and reduce deleterious phlegms in the product.

I've recently learned of the efforts of Edouard Adam. You can find a discussion of his patent, and the follow-ons (not necessarily better) of his competitors in the book

Short History of the Art of Distillation from the Beginning until the Death of Cellier Blumenthal

There's a copy on Google books with most of the pages.

[Melkon Khosrovian]

I'm a bit late coming back to the revival of this discussion, although I have kept an eye on it over the past few months. I really think this is a critical discussion and decision on the part of artisanal distillers. We have to decide who we are, and are not. Or else other will soon decide this for us, to our detriment.

There are some important points that have come up.

Melkon- If we go by part 1 of your definition, there has to be some way to delineate who are distilling their entire product, those who are rectifying spirits by adding artisanal value through infusing and/or re-distillation with botanicals, vs. the supposed craft distillers which just buy spirits, add water, and rectify/re-distill and call it a craft or artisanal product without adding anything positive or discernible to it.

I heartily agree with number 2, 3, and 4.

I also feel that dba's who buy bulk and bottle, or contract to have product bottled, need to be in a separate category, and not artisanal/craft distilling.

Ralph said this quite well, "Craft distillers produce alcoholic beverage spirits by distillation, or by infusion through distillation or redistillation. Maximum production for a "craft" or "artisan" distiller should not exceed 50,000 proof gallons per year. The "craft" or "artisan" distiller utilizes a pot still, with or without rectifcation columns, for distillation of beverage spirits. A distiller starting with neutral spirits produced by others, who redistills without substantially altering the neutral character of the spirit may not be said to be a "craft" or "artisan" distiller."

***

"This definition deliberately excludes producers of infused products making use of alcohol which the producer has not made from the fermentation and/or distillation process. It is inclusive of the distiller who starts with grain neutral spirits and then redistills as a function of infusion or some other process which substantially alters the neutral character of the original spirit. It excludes the distiller who starts with gns and merely runs it through a still again to create another neutral spirit; or starting with grain neutral spirits only adds flavoring and/or color unless those changes are introduced as the result of distillation, not merely as additives. It excludes blenders or bottlers who buy spirits from another distiller to blend and bottle it under another brand. The "distiller" must distill."

Does there need to be sub-categories within the artisanal distilling definition? Some small distilleries are producing minute amounts of product, while others are producing much more. Setting a limit of 50,000 gallons is a good start, but... what about those who produce much less? Should they get there own category, with the possibility of more federal and state economic help and incentives?

We also need to clear the air around the actual definition of the plethora of terms being bandied about: artisanal distilled, craft-distilled/ing, hand-distilled, micro-distilled, micro-batch, nano-batch, nano-distilled, etc.

As I mentioned near the beginning of this thread, but no one responded too, what about Ansley Coale at Hangar One and their trade mark of the term "Craft Distillers?" What impact, or importance, if any, does this have?

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.

[dgpoff]

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.

OK - I think I have it figured out. This is easy - it's all about the focus on the DSP permit.

I propose the following tiers in the new SDSPA (Small DSP Association):

SDSPMDP - Level code Alpha - This Small DSP holder Mashes, Distills, and Packages product. Their group color shall be copper. They will only sit in chairs draped in red at all group functions. Their dues shall be paid in Euros.

SDSPDP - Level code Omega - This Small DSP holder Distills and Packages product. Their group color small be bronze. They must only shake hands with their left hands. Their dues shall be paid is US Dollars.

SDSPP - Level code Delta - This Small DSP holder only packages product. They have no distilling equipment other than a 3 liter coffee pot still they bought on ebay. Their group color shall be orange - as in the threat level orange. They must sport a tattoo of their logo somewhere above the belt line. Their dues shall be paid in copper scrubbing pads.

SDSP - Level code Zeta - This Small DSP holder does whatever in the hell he or she wants. They don't make or package anything. They are "worried about small distilling and world peace." Their group color shall be red. They will be granted permanent access to every other members facilities so they can "borrow" some stuff with promises of an speedy return. This group shall have no dues as they live off the work of others.

See, That wasn't so hard.

Don

Proponent of SDSPA

[Ralph at Tuthilltown]

This is getting a little silly, everyone picking apart all the details. Anyone with half a notion where the industry is headed can not disagree our nascent industry needs to act together to get where we need to go.

Perhaps here is a good point to talk about the nature of the organization. Should the ADI continue to keep "distiller" in it's title, or broaded its mandate to include all small craft spirits producers. Within the organization we can call ourselves anything we elect: Distiller, Rectifier, Blender, Infuser, etc. But to the Fed and States and Big Alcohol, we need to be one group of small producers.

There is NO point, at this point, in debating whether a craft distiller uses a column, or pot still or puts a tea kettle on the kitchen stove. And those who spend their wee hours in the shop crafting spirits from varieties of herbs and fruit is performing a "craft" as well as any other producer whose product is that of a craft.

It is not the spirits which determine the nature of the producer, it's how he produces and what he puts into it of himself. It is time to get over the distinctions for the time being and focus on the real issue, lobbying power at the Fed, State and with DISCUS.

R

[Paul G]

This is getting a little silly...

I think a little silliness has its practical purpose of keeping people from taking themselves TOO seriously

Paul G - Shoeshine boy during the day, SDSP Zeta Commando by the light of the moon.

*cue ominous theme music*

Don't ask me where I got the spandex outfit with the scarlet zeta...trade secret donchaknow.

[delaware_phoenix]

I'm with Ralph on this. He and Brian are the founders of the craft distilling "industry" in New York and I have the deepest respect for them. They have continually made the extra effort to promote this business, when they could have sat back and simply promoted themselves and their own spirits.

I don't think it's necessary to change our name, even if some members are making specialty infused spirits. My guess is that most members will be distillers or involved in distilling spirits. Also, the public seems to be enchanted with distillers and distilling right now, and it would be good to have them supporting us.

Is ADI listed as an Industry Member with the TTB?

On the issue to Distilled Spirits Excise Tax rates, can there be a list of legislators in the Senate and House in the appropriate committees regarding this issue? Is this an actual bill in Congress or a recommendation from TTB? For us to lobby Congress we need to know who to contact.

[Jonathan Forester]

I think this discussion is very important. Maybe it will cause dissension, but that's important as well; because it will cause us to define ourselves. It may be that among us we have different goals and agendas. I have my opinions. I may change them over time, most probably several times as I grow and develop and my needs and wants progress.

Ralph- I think you pointed out the critical piece of information, "the nature of the organization."

Should 'distiller' be part of the title of the organization to be formed? If it is, the definition of the term is important; as are the connotations.

Or should the focus be on the terms 'small', 'artisanal', craft, and 'spirits producers.' While this drastically broadens the category, it also has a different meaning. While it includes distillers, it includes so much more. But is that a good thing? I believe in truth in advertising, being what you claim to be, and not misleading the public.

I agree that the equipment used to distill isn't the issue. But how it is used may be, depending upon the name and purpose of the organization.

Is the organization to be made up of small, artisanal, spirits/liquor producers? Or small, artisanal, distillers?

I haven't made up my mind about all the connotations of leaving out the critical word, 'distillers.' I personally feel that going with the category 'spirits/liquor producers' opens the door to more than I would like. I, and my partners, have had several discussions about What we will and won't do and How we will and won't do it.

Sure, we can jump into the over-saturated vodka market, buy thousands of gallons of neutral spirits, add our fabulous local water, and re-distill it into vodka. Short term it could be very profitable. Maybe long term, if the vodka market doesn't go bust in the next few years. I'm not sure that's what we are about, and I don't feel that's an artisanal or craft product. BUT, infusing and creating flavored artisanal spirits and liqueurs is something I know I am for; as part of the larger package of being a distiller. If that's all you do I think the distinction should be made.

I understand the need to have an organization that can lobby and stand up to the Feds, States, and DISCUS; supporting small producers.

It's what organization and what it stands for; how it defines itself, and its purpose. This is important to me if I am to be part of it. If I don't agree then I can always go my own way, start a different organization, and those who want to be part of that organization can join.

I like the IDEA of the American Artisanal Distillers Association (AADA), more than The American Liquor Producers Organization (ALPO), but it will be a much smaller and quite different organization.

Which one/s do we want to create?

This is getting a little silly, everyone picking apart all the details. Anyone with half a notion where the industry is headed can not disagree our nascent industry needs to act together to get where we need to go.

Perhaps here is a good point to talk about the nature of the organization. Should the ADI continue to keep "distiller" in it's title, or broaden its mandate to include all small craft spirits producers. Within the organization we can call ourselves anything we elect: Distiller, Rectifier, Blender, Infuser, etc. But to the Fed and States and Big Alcohol, we need to be one group of small producers.

There is NO point, at this point, in debating whether a craft distiller uses a column, or pot still or puts a tea kettle on the kitchen stove. And those who spend their wee hours in the shop crafting spirits from varieties of herbs and fruit is performing a "craft" as well as any other producer whose product is that of a craft.

It is not the spirits which determine the nature of the producer, it's how he produces and what he puts into it of himself. It is time to get over the distinctions for the time being and focus on the real issue, lobbying power at the Fed, State and with DISCUS.

R