Saturday, February 8, 2014

Ten Planks of Government Regulation Blog Series

I guess it's high time that we start blogging it out. 

Here's an update on where we're at:  We're waiting on state paperwork.  Not much of an update!

Really though, we're looking at being open for growler fills, keg sales and peddling to finer restaurants and bars near you by March!  That's big news! We'll be keeping everyone updated on how the paperwork's going, and how "renovations" and moving in our equipment is going in real-time from here on out!

So on the subject of paperwork, let's go ahead and categorize this blog post.  We're going to throw it in the "Ten Planks of Regulation" bucket.  Anything and everything relating to red tape will be lumped into this category.  Feel free to comment and discuss; not all regulations are without merit, but many of them are.  Let the open mockery presented in the blog spur discourse!

As you can see in the un-proofread document below, in the eyes of the TTB we're an officially licensed brewery!  That's right, they didn't run a spell check on it.  

Right now, our application for Farm Brewery status with NYS is in the mail.  It's always a waiting game. Before you brew (we're talking mashing in here, not even fermenting), you need to get your State license. Before you apply for your State license (which can take months), you need to have your Federal Brewer's Notice in hand.  Before you have your Federal papers in hand, you need to have a signed lease.  In order to get a signed lease with any landlord, even if he's your pal, you're going to be paying rent.  If you own the place yourself, well, that's a different blog for a different brewer.  This is MY rant, buddy! 

I know, you're doing the math in your head.  Don't, it's depressing.  It's one of the many barriers to getting into virtually any business, but it's a little different when you're manufacturing alcohol. 

Everyone knows someone who knows someone who owns a bar, a liquor store, or is a State Permit holder. We hear that's tough enough as it is.  When you're making the booze, though, you need Los Federales to sign off on your endeavor first.

Well, the TTB performs a very vital function: tax collection.  So it says on their website:


"TTB's mission is simple...to collect alcohol, tobacco, firearms, and ammunition excise taxes that are rightfully due; to protect the consumer of alcohol beverages through compliance programs that are based upon education and enforcement of the industry to ensure an effectively regulated marketplace; and to assist industry members to understand and comply with Federal tax, product, and marketing requirements associated with the commodities we regulate."

In order to collect the taxes that are rightfully due, and to protect the consumer from your evil death-liquid, the TTB needs your bank statements, your business plan, all your corporate documents, your lease, your driver's license, site diagrams, five character references, a written description of how brewing works, a written narrative describing the premises (including the size, material and orientation of windows, floors and doors), all of the artwork that will go on your product (before you sell it), your recipes, a monthly inventory of grain, fermenting beer, fermented beer, kegged beer, and a bond in the amount next year's estimated excise tax  (in case you don't pay your excise taxes, this way they can take it).  

Submit all that...then they'll do a background check for a few months; something that a new employer typically will take a day to do.  They'll then juggle your application around, oblivious to the fact that you've submitted a lease (every day they spend gawking at your application is money hemorrhaging out of your bank account), and call you back weeks after the anticipated completion date, saying they forgot to ask you for your mother's maiden name.

Phew! There's an end in sight though: You'll finally receive an anti-climactic, stock-standard approval letter, complete with egregious typographical errors. Really though, check your spam folder if you apply for one of these licenses.  Your email filter will think that it's someone trying to give you a virus or sell you Cialis.

Don't worry silly Tobacco Tax and Trade Bureau!  I'll proofread that for you! 


Great job! What exactly were you doing for 8 months?
Attached will be your brewer's notice, and you'll pray that it was done correctly, when your Brewer's Notice Serial # is 1.  Just 1.

We're #1!

It's about time to wrap this up.  I don't want to give it all away!  Don't worry, there will be more to come.  This concludes the first installation of the "Ten Planks" series.  Thanks for tuning in!