Comment 04116504 From: Janine Sturdavant [alewifejs@yahoo.com] Sent: Saturday, September 24, 2005 1:42 PM To: Rulemaking, TTB Subject: Notice #41 Golden City Brewery 920 12th Street Golden, CO 80401 September 24, 2005 Frank Foote Chief, Regulations and Rulings Division Alcohol & Tobacco Tax & Trade Bureau 1310 G Street, N.W. Washington, DC 20005 Re: TTB Notice # 41 Dear Mr. Foote: I am concerned about the possible impacts to my business, Golden City Brewery, should any new mandatory labeling requirements such as those proposed in Notice 41 be enacted. I am in favor of allowing producers the ability to provide additional label information on a voluntary basis. I believe that the implementation of the requirements contained in Notice 41 would cost my small business somewhere between 20% to 40% of gross annual sales the first year. This would be a blow that we might not be able to overcome. At the very least, our debt load would increase significantly. Most small brewers would be facing costs both short and long-term. The almost certain need to purchase new labeling equipment or upgrade what is already in place, would impose immediate significant costs and would also entail a disruption of packaging operations during installation. Add to this the cost of label redesign and new label stocks and the costs associated with lab testing equipment or services, and significant financial burdens would be placed on my business. On the long-term side, I have a real concern with the effects such requirements might have on the ability of brewers to produce seasonal beers or develop new styles and offerings. Golden City Brewery produces seasonals in small quantities, and also provides private labels for charity events and parties.. I believe that enacting any mandatory labeling provisions such as those contained in Notice 41 would be detrimental to individual businesses, the industry and the consumer. As a small brewer, we do not have the economies of scale enjoyed by the mega-breweries. Any mandatory label changes such as those proposed will limit our ability to compete in our local markets . Thank you for your consideration of my comments before reaching a decision on this matter. Sincerely, Janine M. Sturdavant, Managing Partner __________________________________ Yahoo! Mail - PC Magazine Editors' Choice 2005 http://mail.yahoo.com