As the only non-profit trade organization managed by and for craft distillers, our formal response to TTB will carry strong weight with TTB and will be impactful to their rulemaking process.Our formal comments will be generated with a focus on truly reflecting the needs of the industry following a tremendous effort to solicit, collect, integrate and include valuable feedback from across our membership.
Our responses will be crafted in consideration of the following criteria:
– Do they further the mission of ACSA, to elevate and advocate for the community of craft spirits producers? Has the feedback from our member producers been fully solicited, considered and understood? Are our comments professional, written and supported in a way that will give them the best possible chance of being heard and incorporated by TTB? Will acceptance of our proposed changes improve the business climate for craft spirits producers?
– Are our proposals inside the scope of TTB’s regulatory enforcement? Are they enforcable at all? Of course there are probably some things we would like to see happen, but if they fall outside of what TTB is allowed to do then advocacy for those positions must be conducted outside the context of this proposed rulemaking. We won’t forget, we just won’t put them in THIS letter.
We need your comments by January 7, 2019.
