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You aren’t hearing as much about the Rocks District as you should be. You might be surprised why.

I’m not sure there’s any American Viticultural Area (AVA) as aptly named as the Rocks District of Milton-Freewater. Located in north-east Oregon just 15 minutes south of the city of Walla Walla, Washington, it’s the closest thing I’ve ever seen to the look of Chateauneuf-du-Pape. Vines grow in deep beds of basalt cobblestones, the product of ancient volcanic eruptions, rolled and smoothed as they were tumbled down from the nearby Blue Mountains by the Walla Walla River and then deposited on the valley floor in an alluvial fan. Adding to the region's allure, it sits at roughly the same latitude as the southern Rhone. A majority of the vines are Rhone-derived; more than 45% of the vineyard acres are planted to Syrah, with other Rhone grapes like Grenache, Picpoul, Bourboulenc, Clairette, Grenache Blanc, and Roussanne all represented too. In just a few short years, the Rocks District has built a reputation as a place to find some of the most interesting Rhone varieties in America.

Rocks District Vines - Closeup

Neil, Cesar Perrin, Nicolas Brunier and I had the pleasure of exploring this remarkable terroir with Delmas Wines’ Brooke Robertson while we were in town for the recent Hospice du Rhone celebration.

Jason  Neil  Cesar  and Nicolas with Brooke Robertson

If great wines are borne out of struggle, this region is destined for greatness. Not only do the vines have to navigate the rocks and the paltry twelve inches of rainfall, but they have to live through winter freezes so cold that most producers (including Delmas) now bury their vines every winter to provide insulation, and then unbury them in time to prune and start the growing season1. The 300 days of sun, the long summer days due to the northern latitude, summer daily high temperatures routinely in the 90s°F and not infrequently in the 100s°F, allow for enough ripening in the short season, which can end with a freeze any time after the calendar flips to October. And did I mention the rocks?

Rocks District Cobbles

At Hospice du Rhone, the wines from Rocks District fruit were among my highlights of the Grand Tasting, with as clear a signature as any AVA or appellation I can think of. The fact that it’s a small AVA (just 3,767 acres, or less than 1% of the acreage within the Paso Robles AVA) surely helps, along with its climatic uniformity, but I think that the rocks themselves play an important role. As in Chateauneuf-du-Pape, those rocks absorb and reflect the sun, warming the ripening clusters, producing rich, powerful wines with a distinctive umami flavor of baked loamy earth.

The AVA was created relatively recently, with work beginning in 2011 and formal recognition from the United States Tax and Trade Bureau (TTB) in 2015. There are now, according to the AVA’s website, 52 vineyards encompassing 640 acres. More than 50 wineries source fruit from these vineyards, although there are only five production facilities within the AVA’s boundaries. Many more facilities are just a few minutes away, in Walla Walla, the center for wine production (and wine tourism) in the area, and the namesake of the larger AVA in which the Rocks District is nested. And that distance, minor though it seems, provides one of the region’s biggest challenges.

In the federal regulations that govern the American Viticultural Area (AVA) system2, there’s a clause that I’d never noticed before this visit. It says that a wine may be labeled with a viticultural area appellation if it satisfies a series of criteria, one of which is that “it has been fully finished within the State, or one of the States, within which the labeled viticultural area is located”. This clause means that all the wineries with production facilities in Walla Walla (in Washington State) can’t label their Rocks District vineyards with its AVA because that AVA lies entirely in the state of Oregon. Delmas is one of those wineries, so their labels just say Walla Walla.

Neil, Cesar, Nicolas and I were frankly flabbergasted by this restriction when we learned about it. After all, what does a state boundary (or for that matter, where a production facility is located) have to do with viticultural distinctiveness? It seemed to me that this goes against the stated purpose of an AVA, which as explained on the TTB’s website, is:

“An AVA is a delimited grape-growing region with specific geographic or climatic features that distinguish it from the surrounding regions and affect how grapes are grown. Using an AVA designation on a wine label allows vintners to describe more accurately the origin of their wines to consumers and helps consumers identify wines they may purchase.”

That I never knew about this clause in the AVA regulations stems from California’s central place in the firmament of American wine. We’ve never seriously thought about getting fruit from other states. We’re excited, with the launch of our Lignée de Tablas program, to explore other California AVAs, and that’s no problem. But the fact that we can get fruit from the Sierra Foothills (6 hours away from Paso Robles) and use their AVA but Delmas can’t get fruit from their own vineyard, 15 minutes away from the winemaking facility they share with dozens of other local wineries, feels unfair.

The TTB in fact foresaw the challenge that the creation of this new Oregon AVA so close to the region’s winemaking nexus in Washington state would pose for producers. In the 2014 notice of proposed rulemaking for the Rocks District AVA, they solicit feedback on the topic:

“TTB is interested in comments from persons who believe they may be negatively impacted by the inability to use ‘The Rocks District of Milton– Freewater’ as an appellation of origin on a wine label solely because they use facilities located in Washington.”

The TTB must have received enough feedback to convince them that there was support for modifying their rules, because the next year they proposed a rule change to address it:

“The Alcohol and Tobacco Tax and Trade Bureau (TTB) is proposing to amend its regulations to permit the use of American viticultural area names as appellations of origin on labels for wines that would otherwise qualify for the use of the AVA name, except that the wines have been fully finished in a State adjacent to the State in which the viticultural area is located, rather than the State in which the labeled viticultural area is located. The proposal would provide greater flexibility in wine production and labeling while still ensuring that consumers are provided with adequate information as to the identity of the wines they purchase.”

I would have thought that the TTB’s proposed rule change would have been uncontroversial, but it ended up far from the case. Organizations that submitted letters in opposition included Napa Valley Vintners, Family Winemakers of California, the Washington State Wine Commission, and the California Wine Institute. Some included proposed changes that would satisfy their concerns, while others just requested that the proposed new rule be scrapped. Even the Oregon Winegrowers Alliance & Walla Walla Wine Alliance submitted a comment in opposition, although the change that they requested was minor. In every case, the stated reason for opposition was because the regional associations worried that state laws that modify the federal regulations overseeing wine production would be unenforceable in a neighboring state. A good example would be the Oregon requirement that to be varietally labeled, a wine must contain 90% of the listed grape, a more restrictive standard than the federal requirement that a varietal wine contain at least 75% of the named grape.

A few of the comments hinted at a second reason: that they were worried that if a cheaper nearby state could make wine from a prestigious appellation, there might be an exodus of jobs to that lower-cost (or less regulated) state, with economic damage to the established reason.

As typically happens when it receives conflicting feedback, the TTB backtracked and the proposed change was never made. This may have avoided the unintended consequences that the regional associations were worried about, but it leaves the producers in the Rocks District with the same challenge that the TTB identified back in 2014. Are they supposed to all build wineries in Oregon when they’re already established in Washington State? Or establish the reputation of their new AVA without the powerful tool of identifying the wines’ place of origin on their labels?

I don’t have a lot of sympathy for the economic argument (made mostly by commenters from the Napa Valley) given that California is already so large, and with such different costs of production, that any negative damage would likely have already happened. Does Napa Valley’s economy suffer when a Paso Robles winery buys grapes and puts out a Napa Valley AVA wine? I don’t see it.3 And even if you did see it, given the size of California, that ship has sailed. 

The other objection, that state wine laws that try to ensure a higher quality product would be unenforceable out-of-state, doesn’t seem to me like an unsolvable problem. In fact, the Wine Institute proposed an elegant solution in their comment objecting to the proposed rule (their addition emphasized):

“(iv) In the case of American wine, it has been fully finished (except for cellar treatment pursuant to §4.22(c), and blending which does not result in an alteration of class and type under §4.22(b)) within the State the viticultural area is located in or an adjacent state, or for, a viticultural area located in two or more States, within one of the States in which the viticultural area is located, and it conforms to the laws and regulations governing the composition, method of manufacture, and designation of wines in all of the States where the viticultural area is located.

It seems to me like this solution gives something to everyone. Appellations like the Rocks District get to build their reputation by appearing on wine labels. Winemakers get the flexibility to source grapes from diverse regions and tell consumers where they come from, without having to build new wineries across state lines. Grape growers are able to benefit from the reputation of the region they help establish. States retain the ability to enforce regulations designed to enhance quality or distinctiveness. And consumers get more clarity on where the wines they love come from. Let's hope that the TTB revisits this issue soon, with a more tailored approach.

Meanwhile, go out and do a little research on which Walla Walla AVA wines actually come from the Rocks District, and try to find a bottle or three. You won’t be disappointed.

Delmas Bottle

Footnotes:

  1. How cold? This January 13th, the low was -8°F and the high just 4°F.
  2. That would be the Federal Register Title 27 Chapter I Subchapter A Part 4 Subpart C § 4.25(e)(3)(iv) for anyone keeping score.
  3. I would also note that I think this argument raises commerce clause objections about a state using regulation to protect its businesses from competition from competing businesses in other states.

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