Parley s Place Bistro Bar Kimberly Vitaly Paley - View Comments

Comment 71 Dear Sirs/Ladies: I am writing in support of the Eola Hills AVA petition, as published in the Federal Register (RIN # 1513-AA41). I am in general agreement that the AVA proposals are accurate and beneficial, with reasonable boundaries and differentiating characteristics. I am convinced that, by its nature, the AVA will help consumers more reliably select wines that meet their expectations, based on where the fruit for these wines is grown and the consistently identifiable characteristics from that region's, soils and climate. I believe that the name chosen to identify this AVA is the most appropriate one, and that, in a sense of fairness, the AVA, since it uses a name which currently identifies a longstanding winery (having existed greater than 10 years) which also sources fruit from a proposed AVA other than the one bearing its name, should be permitted to operate as if it meets 27 CFR 4.39(i) requirements. I hold the view that July 7, 1986 was set somewhat arbitrarily at the time of rulemaking in 1988, identifying a date far enough in the past to assure no opportunism was at play, but that, as a result of it being a discrete date rather than a moving period of time, unfairly punishes those wineries such as Eola Hills Wine Cellars (and also Chehalem in the proposed Chehalem Mountains AVA) from younger wine regions which have existed ten years or more. Modification of the rules to recognize an elapsed time period, or to "grandfather" the wineries, would be appropriate. With the above modification, I ask that the AVA for Eola Hills be approved. Sincerely Kimberly Paley Paley’s Place Bistro & Bar Portland, OR 97209 Tel.: Fax: e-mail: