by Andrew Chalk
The public comment period on a rule change that I proposed to the Texas Department of Agriculture (TDA) – that a wine carrying the ‘Go Texan’ mark be required to be made only from Texas grown grapes – ended in December. We are now in a second public comment period that ends on February 10th. In the meantime, I have obtained the submissions of the first public comment period and analyzed them. The results are interesting…
69 comments were received by the TDA;
I divided the results into five categories.
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Those favoring a minimum of 0% Texas grapes in Go Texan wine (the current rule)
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Those favoring a minimum of 50% Texas grapes in Go Texan wine;
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Those favoring a minimum of 75% Texas grapes in Go Texan wine;
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Those favoring a minimum of 100% Texas grapes in Go Texan wine;
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Those not expressing an unambiguous view about the percentage or not identifying their category (consumer, winery, etc.). Not all responses came down to expressing a percentage (one person even went to the trouble of sending an ad hominem attack on me to the TDA – how thoughtful). 10 responses fell in this category, leaving us with a final sample of 59.
The grid below shows the number and percentages of respondents in each category that expressed an opinion on the minimum grape percentage in a Go Texan wine.
|
0% RULE |
50% RULE |
75% RULE |
100% RULE |
TOTAL |
|
|
CONSUMERS |
1 (5%) |
2 (10%) |
1 (5%) |
16 (80%) |
20 |
|
POLITICIANS |
3 (100%) |
3 |
|||
|
VINE GROWERS |
1 (25%) |
3 (75%) |
4 |
||
|
WINERIES |
19 (59.38%) |
1 (3.13%) |
5 (15.63%) |
7 (21.88) |
32 |
|
TOTAL |
24 |
3 |
6 |
26 |
59 |
The most striking numbers are:
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80% of consumers favor the 100% rule and only 1 consumer (the one who wrote the touching personal attack) opposed it.
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All Texas grape growers responding favored the 100% rule or a 75% rule;
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The proportion of Texas wineries favoring the 0% rule is only 59.38%. In other words, four tenths of Texas wineries themselves believe that the 0% rule is bad for them (undermines the credibility of the Go Texan program, discourages Texas wineries and grape growers, etc.). I find these proportions encouraging.
In fact, many of the wineries that supported the existing 0% rule seemed to do so because they misunderstood the change.
-
The 100% rule would not come into effect overnight. I envisage that it would be phased in. For example, 75% Texas fruit for wines introduced into commerce after January 1st, 2016; 100% Texas fruit for wines introduced into commerce after January 1st, 2018. That way, the planting can start now.
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The 100% rule would apply to each wine. So Go Texan could be used on a wine label if that wine met the 100% Texas grapes criterion. Other wines in the wineries lineup could be less than 100% Texas fruit without affecting this.
Several wineries made a strong case for a 75% rule. This, they pointed out, would be consistent with Federal labelling standards and would be enforced by TTB tax inspections. I agree that 75% would be better than the current rule in that it would prevent the bulk juice mixers from using the Go Texan to sell out-of-state bulk wine. However, it would remove the other purpose of the 100% rule — providing a uniform method for producers to show consumers on their front labels that their wine was made from 100% Texas fruit.
Finally, the arcane word of rule making is interesting. It is clear from some of the winery responses that this is usually a discussion solely between competing producer interests. Witness to this was that four of the wineries spoke in their comments about the notion of the consumer, of all people, having a say as a kind of gross impertinence. “Have they ever made wine?” All they do is drink it.
Regarding the new TDA comment period: If you have already submitted a comment, you do not need to resubmit it – it will be considered in the final evaluation. If you wish to submit a comment, or an additional comment, send it by e-mail to gotexan@TexasAgriculture.gov or via mail to to Mr. Bryan Daniel, chief administrator for trade and business development, Texas Department of Agriculture, P.O. Box 12847, Austin, Texas 78711.
***Crickets***
From what I have seen (minus 1 winery which I think should be ashamed of themselves) only those wineries involved in passing off jug wine as Texas wine are the ones who are to screaming about this.
Even a few (and I know who they are…they will also be added to my black list of Texas wineries I refuse to support) have the arrogance and audacity to give the connotation that their Consumers are “Stupid” (I read the exact written remarks myself)
After all it is only a little icon….what does it matter? It is not like GoTexan is going to not let you be member if you do not make 100% Texas wine all the time.
If these wineries are depending on that mark to sell their wine then seriously they need a new business model….. Just saying
Here is the REAL deal, maybe it was a bad idea that the state spent millions on a PR company (Hahn PR) to push Texas wine through multiple media outlets utilizing bloggers and media connections to hype up many of the facts about Texas wine only to have it dropped on its head by 2013 and 2014 vintages. Not to mention the big media wine dinners where media was drinking and dining on Texas $$$)
Hahn PR also inflated the numbers on many different things and got many uneducated wine people (I was one of those) involved in the excitement of a growing wine industry, the only problem was that when people start to become more and more educated about wine and their palate bean to grow, they started to learn that the information fed to them was not exactly truth and things like this are just a small part of the aftershock you will be seeing for years to come.
If you have bloggers making comments like “Texas wine will always hold its own with wines of the world” or “There is not 1 hill country winery that right now has a wine that can not compete on a global scale” (I am paraphrasing because I do not want to look up the exact quotes at this moment) Yet fuss at people like Andrew Chalk who want legitimacy in your comments, I think all those hyping up Texas wine to the point where it is something it is not need to GO AWAY!
THESE PEOPLE are the ones hurting the industry more than someone asking for transparency and legitimacy…..
THINGS LIKE THIS are only a small part of what we are seeing as results of the Hype created by state funded and blogger promotion of Texas wine.
It seems to me, from reading all the winery comments, that behind closed doors wineries are saying to these bloggers and promoters “SHUT UP SHUT UP SHUT UP! We do not have enough grapes to support all these claims!”
Texas should not talk with arrogance in its mouth when it has to say comments like “we do not have enough grapes to support the demand”
Mark Hymen, I have a new found respect for you sir even though I do not agree with your stance, reading your comments I liked what you had to say, I hope one day to meet you sir!
And
Jeff Cope: You are a Jerk, a crook and very deceptive…. You also are the only person who has thrown around the phrase “Libel” when in fact you yourself are 2 faced. You can not be trusted and had the audacity to post information based on hearsay. You do not want to grow a pair and have a stance in this issue because you do not want to upset any winery that might offer you free wine or an invite.
PS. Jeff I am not a blogger, If I was my blog would have been updated regularly…..its not. I am a consumer unlike you.
As I have said before “Go kiss up to another winery somewhere Jeff and enjoy your free wine” (God knows what other kinds of perks you have received for a good post on your blog)
I honestly do not think that 100% is possible currently but what would be nice to see is just the “Go Texan” mark only be put on “Texas AVA” labeling.
Also too those fussing about how much “Tax payer money” this will take to police, you forget that there are consumers out there that are watchdogs and can report the infractions to the TDA for further investigation. In all Honesty this will not cost THAT much more money. (I bet way less than 2 mill a year)
PSS. The letters submitted are public information and the comments are available to anyone who request them through the “Freedom of Information act” so Jeff We all read your comments…..
Also too Jeff Cope: unlike YOUR blog CraveDFW does not have it set where submissions have to be approved by a moderator…..
You have deleted my comments when I have attempted to post onto YOUR blog. So dont go whining to the state about things you do yourself
You are a 2 face hypocrite!!!
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As I’ve said publically yesterday on FB, at first I thought that you were going down a rat hole with this whole GoTexan thing. But, when I read the comments and your analysis, it all made perfect sense to me…Texas consumers need honest labeling and Texas grape growers need honest wineries! The GoTexan rule change will help on both counts
Sorry I questioned your approach. But, I thank you for doing it. Remember someone said, “I may not agree with what you have to say, but I will die for your right to say it!” Andy, it apply to us too.
Here are my 2nd round comments to TDA GoTexan Program:
I am in favor of fare, honest and accurate labeling for all products. Allowing wineries to use the GoTexan Logo on wine that is made primarily from non-Texas grapes does not accomplish any of these three mandates.
I am in favor of using the well-established and accepted federal TTB regulations that determine the appellation of origin for wines in all states including Texas. This is the 75% rule that requires a minimum of 75% of the grapes used in a wine that carries a state’s appellation. The same should be mandated for a wine that includes the use of the GoTexan logo.
This approach, based on 75%, is better and more workable than a 100% rule. The 75% rule provides 25% margin for wineries to use grapes from other sources if and when needed due to the year-to-year variations in harvest conditions and availability of wine grapes within the state.
Dr. Russell D. Kane
Andy,
When is this going to be resolved with the revised requirements for Go texan from TDA?
Russ