HomeMy WebLinkAboutZTA201600003 Correspondence Zoning Text Amendment 2016-09-21 Amanda Burbage
From: Craft, John (ABC) <john.craft@abc.virginia.gov>
Sent: Wednesday, September 21, 2016 12:04 PM
To: Amanda Burbage
Subject: RE:ABC licensing question
Follow Up Flag: Follow up
Flag Status: Flagged
Hi Ms. Burbage-
ABC Licenses are not transferable between locations. If an existing licensee desires to be licensed at a new address, they
must apply for a new license.
A farm winery does not need a winery license at another vineyard to utilize the fruit, but only a lease of the property where
the vineyard lies. A farm winery's"farm" is defined as the area where they are licensed, and any other"leased" areas.
They could not manufacture and sell wine at the site of another vineyard (unless they applied for and receive a remote
approval), but the other vineyard under lease would be considered their fruit for the purposes of maintaining the 51% from
their own farm criteria.
I hope this is helpful.
Sincerely,
John
John K. Craft I Senior Special Agent,Compliance Unit I Virginia ABC
Bureau of Law Enforcement 1460 Commerce Square,Staunton,VA 24401
Office:(540)332-7803 I Fax:(540)332-7814 I John.Craft@abc.virginia.gov
Facebook and Twitter:VirginiaABC
Confidentiality Statement
From: Amanda Burbage [mailto:aburbage@albemarle.org]
Sent: Wednesday, September 21, 2016 9:38 AM
To: Craft, John (ABC)
Subject: ABC licensing question
Good morning Agent Craft,
I have another question for you about ABC licensing for farm wineries, breweries&distilleries. If an establishment
relocates to a new property, are they able to retain the same ABC license?Also, is it possible for an individual license to
be tied to more than one property (such as if a winery grows grapes on more than one property)?
Thank you,
Amanda Burbage LEE D
Senior Planner
County of Albemarle
Department of Community Development,Zoning Services
401 McIntire Road
Charlottesville,VA 22902 4596
h f4:14 2V-'y,<1,2 tS'2 c.),< M2
aburbaae(r6albemarle,ora
1
Meeting with ABC Agent John Craft
10-7-2015
FW—farm winery; FB —farm brewery; FD —farm distillery (some of these are our words
and ABC uses "Limited" for brewery and distillery)
Retail licensing is different from wholesale licensing. Rules (VAC) are Virginia
Administrative Code and are not black & white at the request of ABC. For example,
"We take no objection to X."
Farm Brewery — have to grow something on the farm and use it in something that is
produced on the farm. Doesn't say how much. Small amount of early growing (shoots)
has been approved by the appeal board in at least 1 case.
We now have 260 wineries in Virginia. There's a limited supply of grapes.
License holder can chose to surrender their license.
Alcohol and Tobacco Tax and Trade Bureau (TTB) is the federal licensing agency for
these. Each winery, brewery and distillery manufacturer or wholesaler - requires federal
approval first before they can obtain a state licenses.
ABC uses a standard retail application to also cover FW, FB and FD. Initial application
goes to Richmond for review for completeness. Posting and publishing about a license
application has a 30 day comment/objection period. Agent does site visit and meets
with the applicant — looking for a producing vineyard and equipment onsite. Have to
produce some amount onsite but that amount is undefined. Can contract to make most
of it off-site (previously called "custom crush" and now called "contract winemaking").
FW Class A must be held for 7 years before can obtain Class B. (Only about 3 Class
Bs in VA). Class B more expensive and removes some of the limitations on growing.
The "farm" is the area of the license as well as other leased locations. Class A requires
51% to be grown on the farm, 25% elsewhere in VA and 24% can be out of state).
It takes 3-5 years (ideally 7 years) for grapes to be mature enough to be usable for wine
production.
All licenses are renewed annually. However, it doesn't require a re-inspection and is
largely a paper exercise. No minimum production is required to maintain the license.
General Assembly may possibly consider further provisions for collaborative brews.
Now, the sales are limited to one brewery.
COUNTY OF ALBEMARLE
K�OAF
AtkL.
`rRG1141
MEMORANDUM
TO: Albemarle County Board of Supervisors
FROM: Greg Kamptner,Deputy County Attorney
DATE: November 30,2015
RE: Farm wineries,farm breweries, and farm distilleries;whether the County may impose additional or alternative
requirements to those required for State licensure in order for a farm winery,farm brewery, or farm distillery to be
classified as such
This memorandum addresses whether the County may impose additional or alternative requirements to those
required for State licensure in order for a farm winery, farm brewery, or farm distillery to be classified as such.This
memorandum focuses on farm wineries.
1. Introduction
Farm wineries are licensed by the State under the Alcoholic Beverage Control Act,and their qualifications are
described in various sections of Title 4.1 of the Virginia Code. Farm wineries are also licensed under federal law by
the Alcohol and Tobacco Tax and Trade Bureau, and the federal license is required before a prospective farm
winery may obtain a State license. This memorandum focuses on the State licensing requirements.
The Alcoholic Beverage Control Act defines "farm winery"in two different ways, and those two definitions
coincide with the two classes of farm winery licenses—Class A and Class B farm winery licenses.
2. Class A farm wineries
A "farm winery"is an establishment"located on a farm in the Commonwealth with a producing vineyard,
orchard, or similar growing area and with facilities for fermenting and bottling wine on the premises where the
owner or lessee manufactures wine that contains not more than 21 percent alcohol by volume." Virginia Code 5 4.1-
100 (subdivision (i)in the definition of`farm winery' .This definition coincides with the description and eligibility
requirements for a Class A farm winery license in Virginia Code 9 4.1-219:
For Class A farm winery licensees,at least 51 percent of the fresh fruits or agricultural products
used by the owner or lessee to manufacture the wine shall be grown or produced on such farm and no
more than 25 percent of the fruits, fruit juices or other agricultural products shall be grown or
produced outside the Commonwealth.
As used in this definition of"farm winery," the terms "owner"and"lessee"include a cooperative formed by an
association of individuals for the purpose of manufacturing wine. Virginia Code 5 4.1-100. The term "farm"is
defined to mean "all of the land owned or leased by the farm winery licensee as long as such land is located in the
Commonwealth." Virginia Code f) 4.1-219.This expansive definition of"farm" also applies when the land is owned
or leased by a cooperative. Virginia Code fj 4.1-100.
1
farm winery license for at least seven years. Virginia Code 4.1-219. There are approximately 3 Class B farm wineries
in Virginia.
4. The extent to which a County may impose additional requirements to qualify as a farm winery
Under the Alcoholic Beverage Control Act, the General Assembly has established the minimum qualifications
for licensure and has delegated to the Alcoholic Beverage Control Board,not localities, the authority to administer
licenses. The General Assembly has not granted to localities any express or implied powers to change the terms and
conditions of licensure. Indeed,Virginia Code § 4.1-128 prohibits a locality, except in limited circumstances
inapplicable to land use matters3, from adopting an ordinance or regulation that"regulates or prohibits the
manufacture, bottling,possession, sale,wholesale distribution,handling, transportation, drinking,use, advertising or
dispensing of alcoholic beverages in the Commonwealth."
5. Conclusion
Under principles of pre-emption and the Dillon Rule, the County may not impose additional requirements for
State licensure or to qualify as a farm winery, farm brewery, or farm distillery under Virginia Code §§ 15.2-2288.3,
15.2-2288.3:1, and 15.2-2288.3:2. For example, the County may not impose minimum site acreage requirements,
minimum agricultural production acreage requirements, or other standards in order to qualify as a farm winery, farm
brewery, or farm distillery.
3 The General Assembly has authorized localities to adopt regulations prohibiting the consumption of alcoholic beverages in public,at public schools,
3
Based on the foregoing, a Class A licensee must produce at least 51 percent of the fresh fruit or agricultural
products used in the manufacture of its wine on the farm that it owns or leases. The remaining 49 percent may be grown
elsewhere and by somebody else,provided that not more than 25 percent of the fresh fruits, fruit juices, or
agricultural products are grown outside of the Commonwealth.
A Class A farm winery may enter into an agreement in accordance with State regulations with another winery or
farm winery licensee that operates a contract winemaking facilityl (commonly referred to as "custom crush").
Virginia Code 5 4.1-207(5). The custom crush facility may manufacture some or all of the wine for the farm winery.
Even though the custom crush facility may manufacture all of the wine, a farm winery,by definition,must have
"facilities for fermenting and bottling wine on the premises where the owner or lessee manufactures wine." Virginia
Code 5 4.1-100 (applicable to all farm wineries).
The Class A licensing requirements do not require a minimum amount of wine production. A person who
manufactures wine at his residence for home consumption, and not to be sold or given away,is exempt from the
State licensing requirement if the amount manufactured does not"exceed the limits permitted by federal law."
Virginia Code 5 4.1-200(6). The limit permitted by federal law appears to be the federal threshold at which a
winemaker becomes subject to the federal excise tax for a single household: (1) 200 gallons per calendar year for a
household in which two or more adults reside; or (2) 100 gallons per calendar year if there is only one adult residing
in the household. 27 CFR 5 24.75. A person who manufactures wine at his residence may remove up to fifty liters of
wine on any one occasion for specified and limited purposes,including personal or family use. Virginia Code,I 4.1-
200(6).
In sum,in order for a prospective farm winery to obtain a Class A farm winery license, at least 51 percent of the
fresh fruits or agricultural products must be grown on a farm that it owns or leases. Class B farm wineries, discussed
below, are not subject to the same requirement.2
3. Class B farm wineries
The second definition of"farm winery"is an establishment"located in the Commonwealth with a producing
vineyard,orchard,or similar growing area or agreements for purchasinggrapes or other fruits from agricultural growers within the
Commonwealth, and with facilities for fermenting and bottling wine on the premises where the owner or lessee manufactures wine that
contains not more than 21 percent alcohol by volume." Virginia Code 5 4.1-100.This definition coincides with the
Class B farm winery license,which is described in Virginia Code § 4.1-219 as follows:
For Class B farm winery licensees, 75 percent of the fresh fruits or agricultural products used by the
owner or lessee to manufacture the wine shall be grown or produced in the Commonwealth and no
more than 25 percent of the fruits, fruit juices or other agricultural products shall be grown or
produced outside the Commonwealth.
Class B farm winery licensees are not required to be located on a farm and, even if they are located on a farm,
they are not required to use any fresh fruits or agricultural products grown on the farm in the manufacture of wine.
In order to be eligible for a Class B license, the farm winery is required to have operated under an existing Virginia
"Contract winemaking facility"means the premises of a licensed winery or farm winery that obtains grapes,fruits,and other agricultural products from a
person holding a farm winery license and crushes,processes,ferments,bottles,or provides any combination of such services pursuant to an agreement
with the farm winery licensee.For all purposes of this title,wine produced by a contract winemaking facility for a farm winery shall be considered to be
wine owned and produced by the farm winery that supplied the;rapes,fruits,or other agricultural products used in the production of the wine.The
contract winemaking facility shall have no right to sell the wine so produced.unless the terms of payment have not been fulfilled in accordance with the
contract."Che contract winemaking facility may charge the farm winery for its services. Virginia Code§4.1-100.
z The licensing requirements for farm breweries and farm distilleries are somewhat similar to one another but dissimilar to those applicable to farm
wineries.The licensing requirements for farm breweries and farm distilleries establish an annual maximum limit on the gallons of the alcoholic beverage
produced,and require that they be located on a"farm"on"land zoned agricultural"and that the"agricultural products used by"the brewery or distillery in
the manufacture of its alcoholic beverages are"grown on the farm."Virginia Code§§4.1-206(2)(farm distilleries),4.1-208(2)(farm breweries).Farm
wineries,on the other hand,do not have a maximum limit on the bottles or gallons of wine produced and are not expressly required to be located on
agriculturally-zoned land.
2
COUNTY OF ALBEMARLE
AO'A
MEMORANDUM
TO: Albemarle County Board of Supervisors
FROM: Greg Kamptner,Deputy County Attorney
DATE: November 30,2015
RE: Farm wineries,farm breweries, and farm distilleries;permissible scope of County regulation under Virginia Code
55 15.2-2288.3, 15.2-2288.3:1, and 15.2-2288.3:2
This memorandum addresses the permissible scope of regulation of farm wineries,farm breweries, and farm
distilleries by the County under Virginia Code §§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2.
1. Introduction
Although the County has been delegated broad powers to regulate land use and to establish zoning districts
under Virginia Code § 15.2-2280, the General Assembly has limited and partially preempted those broad powers in a
range of areas,including farm wineries,farm breweries,and farm distilleriesl.
Under the State's zoning laws,the relevant section of the Virginia Code applicable to farm wineries is Virginia
Code§ 15.2-2288.3;the relevant section applicable to farm breweries is Virginia Code§ 15.2-2288.3:1;and the
relevant section applicable to farm distilleries is Virginia Code § 15.2-2288.3:2. Each of these sections was adopted at
different times as part of legislation that also amended various provisions of the State's alcoholic beverage control
laws in Title 4.1 of the Virginia Code.
The three statutes (Virginia Code §§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2) contain similar elements:
• A statement of policy to preserve the particular industry,maintaining appropriate local land use authority to
protect the public health, safety, and welfare,and permitting the reasonable expectation of uses in agricultural
zoning districts (omitted from Virginia Code § 15.2-2288.3:2 (farm distilleries)).
• A list of activities that localities are expressly prohibited from regulating. These activities include the actual
production and harvesting of the agricultural products used in the alcoholic beverage,on-premises sale, tasting,
and consumption during regular business hours,the sale, shipment,and storage of the alcoholic beverage,and
the sale of items related to the alcoholic beverage.
£ • A statement that any regulations pertaining to activities and events to market and sell the products
"shall be reasonable" and must"take into account the economic impact" of the regulation,the
"agricultural nature"of the activities and events, and whether the activities and events are "usual and
1 Virginia Code§§ 15.2-2288.3:1 and 15.2-2288.3:2 use the terms"limited brewery"and"limited distillery,"respectively.However,the County's zoning
ordinance uses the term"farm brewery,"and it is anticipated that it will also use the term"farm distillery"when the regulations for that use are adopted.
Thus,"farm brewery"and"farm distillery"are used in this memorandum.
1
•
customary" at farm wineries, farm breweries,or farm distilleries. (boldface added)
• If an activity or event is determined to be usual and customary,it must be permitted unless there is a
"substantial impact on the health, safety,or welfare of the public." (boldface added)
• A requirement that the regulation of noise applicable to the activities and events may not be more restrictive
than the standards in the locality's general noise regulations;provided that noise generated by"outdoor
amplified music"may be separately regulated and even prohibited,considering the effect on adjacent property
owners and nearby residents.
The farm brewery and farm distillery statutes also include a provision allowing a locality to exempt the use
"from any local regulation of minimum parking,road access,or road requirements."
The two elements that have been highlighted in boldface are the focus of the remainder of this memorandum.
2. The County may regulate activities and events at farm wineries, farm breweries, and farm distilleries as
provided by Virginia Code§§15.2-2280,15.2-2288.3,15.2-2288.3:1, and 15.2-2288.3:2
Under the Dillon Rule,a locality's governing body has only those powers expressly granted by the General
Assembly,powers necessarily or fairly implied from the express powers,and powers that are essential and
indispensable.Jennings v. Board of Supervisors of Northumberland County,281 Va. 511, 516 (2011) ("a locality's zoning
powers are`fixed by statute and are limited to those conferred expressly or by necessary implication").
The first step in a Dillon Rule analysis is whether the local governing body is enabled under any State law.
Marble Technologies v. City of Hampton,279 Va. 409,418 (2010). In this case,the County's power to regulate,restrict,
permit,and prohibit uses is enabled under Virginia Code§ 15.2-2280,generally,but the broad delegation of
authority under that statute has been modified and refined with respect to farm wineries, farm breweries,and farm
distilleries by Virginia Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2.
The second step in a Dillon Rule analysis considers how a locality may properly execute the power granted to it.
There are two alternative rules that may apply,depending on whether the enabling authority species the manner in
which the locality may execute its power. In this case,Virginia Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2
specify the factors that localities must consider in regulating activities and events to market and sell the products and
prohibits localities from regulating usual and customary activities and events unless there is a substantial impact.
Beyond that,a locality's regulations implementing these statutes must be reasonable and exercised under Virginia
Code§ 15.2-2280.
Although the County may not impose additional or alternative requirements to qualify as a farm winery, farm
brewery,or farm distillery,it may regulate the activities and events to market and sell the products by considering
the relevant factors and adhering to the limitations in Virginia Code §§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-
2288.3:2.The analysis in sections 3 and 4,below,examines those factors and limitations.
3. The scope of the power to regulate activities and events at farm wineries,farm breweries, and farm
distilleries
Virginia Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 each provide that any regulations pertaining to
activities and events to market and sell the products "shall be reasonable"and must"take into account the economic
impact" of the regulation,the"agricultural nature"of the activities and events,and whether the activities and events
are"usual and customary" for farm wineries,farm breweries, or farm distilleries. Each of these factors is analyzed
below.
A. Whether the activities and events pertain to marketing and selling the product
The first consideration is whether the activities and events pertain to marketing and selling the product because this
2
consideration determines how the activities and events may be regulated.
11
Virginia Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 do not explain what it means to market and sell the
product. It may be presumed that,at a minimum, the product must be displayed,be available for sale, or be promoted
at each activity or event.
1
If an activity or event does not pertain to marketing and selling the product,then the restrictions of Virginia
Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 do not apply, the analysis under those statutes ends,and the
I
County may regulate the activities and events under its general zoning powers in Virginia Code§ 15.2-2280. In that
j situation, the County would not be required to specifically consider the economic impact of its regulations, the
Iagricultural nature of the activities and events,or whether the activities and events are usual and customary. Of
1 course,any such zoning regulation would have to be reasonable and be within the scope of the County's authority
under Virginia Code§ 15.2-2280.
1
If an activity or event pertains to marketing and selling the product,then the analysis continues to subsection
1 3(B) and section 4,below.
s B. Any regulations must be reasonable
r
A regulation is "reasonable"when it is "[flair,proper,or moderate under the circumstances;sensible."BASF
and James City County v. State Corporation Commission,_Va._(2015). In other words,a reasonable zoning
regulation must serve some legitimate purpose under the zoning power,such as protecting the public health, safety,
or welfare,must be supported by facts, and must regulate in a way that does not impose undue burdens on affected
landowners.The regulation that is not reasonable is one that is "arbitrary and capricious,"which means that the
3 regulation is "willful and unreasonable and taken without consideration or in disregard of facts or without
a determining principle."James v. City of Falls Church,280 Va. 31,42 (2010). Because any valid regulation must be
z reasonable,its express inclusion in Virginia Code § 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 is,in many respects,
6 unnecessary. If nothing else,including the reasonableness requirement in the statutes is a reminder from the General
Assembly to localities of their obligation under those statutes.
In order for regulations of activities and events to be reasonable under Virginia Code§§ 15.2-2288.3, 15.2-
2288.3:1, and 15.2-2288.3:2,the locality must consider the economic impact of the regulation, the agricultural nature of the
1
activities and events, and whether the activities and events are usual and customary for farm wineries,farm breweries, or farm distilleries.
1 Significantly,Virginia Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 only require that these factors be
"take[n] into account"and do not require a particular result after these factors are considered.Thus,these factors
i
serve to guide whether regulations will be deemed to be reasonable, i.e., fair,proper,and moderate.
fi (1) In developing reasonable regulations, the economic impact of the regulations on farm wineries,
1 farm breweries, and farm distilleries must be considered
1 Virginia Code §§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 require that the economic impact of the regulations be
considered when they are developed but do not compel a particular result.
i
ii The economic impact of a regulation may come in several forms,including: (1) the economic impact of being
3 able to adequately market and sell the product; (2) the economic impact resulting from restrictions on activities and
events (e.g.,a restriction that allows no more than 15 people on site at a time or limits activities and events only to
I daylight hours); (3) the cost to obtain approvals required by the regulation (e.g., the cost to apply for a special use
permit or to obtain approval of a site plan); (4) the cost to make required improvement(e.g., the cost to grade and
pave a parking area);and (5) the economic impact resulting from delay in obtaining approvals and installing
improvements.
1
When applied to a proposed regulatory scheme, these considerations may shape the nature and the extent of any
regulation,justify that application fees for legislative and ministerial approvals required for activities and events be
different than those for other uses,justify that processing these applications be expedited or be subject to different
3
•
procedures (e.g.,a sketch plan in lieu of a site plan),warrant the development of staff-administered performance
standards in lieu of requiring legislative approvals,and warrant the creation of site development standards that are
different than those for other uses.
(2) In developing reasonable regulations,the agricultural nature of the activities and events must
be considered
As with the economic impact factor,Virginia Code§§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 require that
al nature ofthe activities and events be considered when proposed regulations are developed,but do not
thea rzculturp p
g
compel a particular result.This factor raises several issues.
First,by directing the County to consider the agricultural nature of the activities and events, the County is
allowed to consider whether and to what extent the proposed classes of activities and events are tied to agriculture.
Those situations where an activity or event's link to agriculture is tenuous or non-existent may tip the scale in favor
of limiting those activities and events that create impacts,particularly in light of the other relevant factors in the
regulatory analysis (i.e.,the economic impact of the regulation and whether the activity or event is usual and
customary).
For example,it is reasonable to conclude that weddings and wedding receptions held at farm wineries are not
agricultural in nature,and merely holding these activities and events on a farm does not necessarily make them
agricultural in nature. However,the County is aware that weddings and wedding receptions are usual and customary
at farm wineries and is informed that regulations prohibiting or severely regulating these activities may have a
significant economic impact.As another example,while a hayride is an activity that clearly is agricultural in nature in
most circumstances,that conclusion will be different if the hayride is conducted at a farm distillery that has only 15
square feet of grains in production on the farm.
Second,this factor makes the amount of acreage in agricultural production a relevant consideration in
determining the agricultural nature of the range of activities and events,as well as their intensity, that should be
permitted and how they should be regulated.2
(3) In developing reasonable regulations,whether the activities or events are usual and customary
must be considered
Virginia Code§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 do not define usual and customary,but the County
added a definition of the term"usual and customary use,event or activity" as part of a 2014 zoning text amendment
as follows:
A use,event, or activity at a farm winery, farm brewery,or agricultural operation that is both
ordinary and commonly practiced or engaged in at farm wineries, farm breweries, or agricultural
operations,as applicable,within the Commonwealth,as determined by objective evidence.
Albemarle County Code 5 18-3.1.
This definition could be further refined because there is one key distinction between Virginia Code§ 15.2-
2288.3 (farm wineries) and Virginia Code§§ 15.2-2288.3:1 (farm breweries) and 15.2-2288.3:2 (farm distilleries).
Virginia Code§ 15.2-2288.3 refers to activities and events that"are usual and customary for farm wineries throughout
the Commonwealth." (italics added)By comparison,although Virginia Code§§ 15.2-2288.3:1 and 15.2-2288.3:2 refer to
activities and events that usual and customary,they do not require that the activities and events be usual and
customary throughout the Commonwealth.Thus,in evaluating activities and events at farm breweries and farm
distilleries,the County is not compelled to consider what is usual and customary throughout the Commonwealth. It
has the discretion to consider what is usual and customary in the County, the region,or the Commonwealth.
2 This issue is different than the issue of whether the County may require a minimum amount of acreage be in agricultural production in order for the use
to qualify as a farm winery,farm brewery,or farm distillery.
4
• • A
There also are two practical differences between the range of activities and events that are usual and customary
at farm wineries and those that are usual and customary at farm breweries and farm distilleries. First,when the
County's farm winery regulations were significantly revised in 2010,both the County's farm winery industry and the
known range of usual and customary activities and events were already well-established. In addition, the County was
aware of a failed farm winery bill that listed activities and events that would have been classified as usual and
customary.We explained the staff's analysis at that time as follows:
County staff worked with staff from other localities in 2007 and 2008 to identify usual and
customary activities at farm wineries. In the 2008 General Assembly Session,FIB 463 would have
amended Virginia Code § 15.2-2288.3 to include a list of usual and customary activities at a farm
winery.Although the bill failed,representatives of the farm winery industry told County staff in a
meeting in 2008 that the farm winery industry would rely on the list of usual and customary uses in
HB 463 as its model.The list below, [with certain exceptions],is based on HB 463. County staff
has considered each of the items on the list and,though not all of these activities have been usual
and customary at farm wineries in Albemarle County, they are all related to agritourism or wine
sales in a way that promotes the particular farm winery or farm wineries in general.
Staff explained during the 2010 farm winery zoning text amendment that including weddings and wedding
receptions as usual and customary events was "based on the HB 463 version of Virginia Code§ 15.2-2288.3 as
subsection (A)(3)(a). If more than 200 persons may attend at any time, a special use permit would be required."
Thus,the County's existing farm winery industry and HB 463 (2008)provided the basis for the range of usual
and customary activities and events the County allows at farm wineries and how it regulates them.Farm breweries
and farm distilleries arrive in the County with a blank slate as to what are usual and customary activities and events
because there is no established farm brewery or farm distillery industry in the County or the region. In addition,a
member of the local government team that worked with the General Assembly and those in the industry promoting
the farm brewery legislation in 2014 stated that those promoting the legislation could not identify what they would
consider to be usual and customary activities and events at farm breweries.
The 2014 zoning text amendment that implemented Virginia Code§ 15.2-2288.3:1 for farm breweries was based
on the guiding principle that farm wineries and farm breweries be regulated the same way. However,the County is
not compelled to conclude that what may be usual and customary activities and events at farm wineries are
necessarily usual and customary activities and events at farm breweries or farm distilleries, or to regulate them in the
same way.
4. If an activity or event is determined to be usual and customary,it must be permitted unless there is a
substantial impact on the health, safety, or welfare of the public.
Virginia Code §§ 15.2-2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 do not define substantial impact on the health, safety,
or welfare of the public, but the County added a definition of the term"substantial impact"as part of a 2014 zoning text
amendment to mean:
An impact that may arise from an event or activity at a farm winery, farm brewery, or agricultural
operation that has a significant adverse effect on: (i) an abutting lot or the neighborhood,including
an impact on any owner, occupant, or agricultural or silvicultural activity;or(ii) any rural road,
natural resource, cultural resource, or historical resource.A substantial impact may result from a
wide variety of factors including, but not limited to, the generation of traffic,noise,dust,artificial
outdoor light, trash,stormwater runoff, and excessive soil compaction;the failure to provide
adequate traffic controls and sanitation facilities;the cumulative effects of large numbers of events
and activities occurring simultaneously,particularly when they are in close proximity to one another
or require travel on the same rural roads;and events and activities that are incompatible with
existing production agriculture.
Albemarle County Code 5 18-3.1.
5
The County's current farm winery and farm brewery regulations establish the attendance by more than 200
people at any time as an additional substantial impact threshold for farm winery or farm brewery events (both terms
are defined),weddings,wedding receptions,and other uses not specifically permitted. If these activities and events
will have more than 200 people at the farm winery or farm brewery at any time,a special use permit is required.
The 200-person threshold was established in conjunction with the 2010 farm winery zoning text amendment.
Staff explained this threshold as follows:
Because HB 463 would have limited usual and customary activities to those which were for fewer
than 200 persons, County staff recommends that this threshold be used.The 200-person threshold
is consistent with other thresholds for events allowed in the Rural Areas zoning district: special
events at farm wineries for up to 150 people under the existing farm winery regulations (County
Code§ 5.1.25(c));by-right festivals for up to 150 people at historical centers (County Code§
5.1.42(j)) (the historical center use classification requires a special use permit);and special events for
up to 150 people (County Code§ 5.1.43(e)) (the special events use classification requires a special
use permit).
Of course,even within the same industry(e.g., farm breweries), the impacts of more than 200 persons attending
an activity or event can be quite different on a 60-acre site or a 1-acre site. On the 1-acre site, the 200-person
threshold may allow the use to be too intensive to provide, for example,adequate on-site parking or adequate water
facilities,or to not adversely impact abutting parcels.
In addition,the impacts of activities and events at farm breweries and farm distilleries may be different than
those at farm wineries.The common understanding is that,as a result of their minimum licensing requirements
under the Alcoholic Beverage Control Act,farm breweries and farm distilleries can be located on smaller parcels
than farm wineries.Although State law requires that licensees be located on a farm and that they use agricultural
products grown on the farm, the State has not established minimum standards for what is a"farm"or the amount
of agricultural products that must be grown on the farm and used in the product. In the absence of these minimum
standards,a small token"crop"is likely sufficient to satisfy State licensing requirements.
5. Conclusion
The County's regulation of activities and events for marketing and selling products under Virginia Code§§ 15.2-
2288.3, 15.2-2288.3:1,and 15.2-2288.3:2 must be guided by considering the economic impact of the regulation,the
agricultural nature of the activity and event,and whether the activity or event is usual and customary for the
particular industry. Considering these factors is essential in order for the regulations to be deemed reasonable. How
these factors are evaluated and what weight may be given to one factor in relation to the other factors may vary
from industry to industry.Any activities and events that are found to be usual and customary may be regulated only
if there is a substantial impact on the public health, safety, or welfare.The threshold for a substantial impact may
vary depending on the nature of the activity or event and the condition of the site.
Although Virginia Code 5§ 15.2-2288.3, 15.2-2288.3:1, and 15.2-2288.3:2 impose some limitations on how the
County may regulate activities and events at farm wineries, farm breweries,and farm distilleries, the statutes also
leave the County with the discretion within the statutory framework to ensure that the health, safety,and welfare of
the citizens of the County are protected while at the same time preserving and promoting the economic vitality of
the respective industries by allowing a reasonable range of activities and events to market and sell their products.
6
Code of Virginia
Table of Contents»Title 4.1. Alcoholic Beverage Control Act»Chapter I Definitions and General Provisions»§4.1-
100.(Effective July 1.2018)Definitions
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This section has more than one version with varying effective dates.To view a complete list of the versions of this section
see Table of Contents.
§ 4.1-100. (Effective until July 1, 2018) Definitions.
Bills amendinF this Section
"Farm winery" means (i) an establishment (a) located on a farm in the Commonwealth on land
zoned agricultural with a producing vineyard, orchard, or similar growing area and with facilities
for fermenting and bottling wine on the premises where the owner or lessee manufactures wine
that contains not more than 21 percent alcohol by volume or(b) located in the Commonwealth
on land zoned agricultural with a producing vineyard, orchard, or similar growing area or
agreements for purchasing grapes or other fruits from agricultural growers within the
Commonwealth and with facilities for fermenting and bottling wine on the premises where the
owner or lessee manufactures wine that contains not more than 21 percent alcohol by volume or
(ii) an accredited public or private institution of higher education,provided that(a)no wine
manufactured by the institution shall be sold, (b) the wine manufactured by the institution shall
be used solely for research and educational purposes, (c) the wine manufactured by the
institution shall be stored on the premises of such farmwinery that shall be separate and apart
from all other facilities of the institution, and(d) such farm winery is operated in strict
conformance with the requirements of this clause (ii) and Board regulations. As used in
thisdefinition, the terms "owner" and "lessee" shall include a cooperative formed by an
association of individuals for the purpose of manufacturing wine. In the event that such
cooperative is licensed as a farm winery, the term "farm" as used in this definition includes all of
the land owned or leased by the individual members of the cooperative as long as such land is
located in the Commonwealth. For purposes of this definition, "land zoned agricultural" means
(1) land zoned as an agricultural district or classification or (2) land otherwise permitted by a
locality for farm winery use. For purposes of this definition, "land zoned agricultural" does not
include land zoned "residential conservation." Except for the limitation on land zoned
"residential conservation, " nothing in the definition of"land zoned agricultural" shall otherwise
limit or affect local zoning authority.
LIS > Code of Virginia> 4.1-219 Page 1 of 1
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§ 4.1-219. Limitation on Class A and Class B farm wineries.
For Class A farm winery licensees, at least 51 percent of the fresh fruits or agricultural products used by the owner
or lessee to manufacture the wine shall be grown or produced on such farm and no more than 25 percent of the
fruits, fruit juices or other agricultural products shall be grown or produced outside the Commonwealth.
For Class B farm winery licensees, 75 percent of the fresh fruits or agricultural products used by the owner or lessee
to manufacture the wine shall be grown or produced in the Commonwealth and no more than 25 percent of the
fruits, fruit juices or other agricultural products shall be grown or produced outside the Commonwealth.No Class B
farm winery license shall be issued to any person who has not operated under an existing Virginia farm winery
license for at least seven years.
However, upon petition by the Department of Agriculture and Consumer Services,the Board may permit the use(i)
of a greater quantity of out-of-state products if supplies grown or produced in the Commonwealth are insufficient for
a farm winery licensee, whether Class A or Class B,to achieve the level of production which otherwise could be
anticipated during a given license year or(ii)by a Class A farm winery of a lesser percentage of products grown or
produced on the farm if unusually severe weather or disease conditions cause a significant reduction in the
availability of fruit or other agricultural products grown or produced on the farm to manufacture wine during a given
license year. As used in this section,the terms "owner" and "lessee" shall include a cooperative formed by an
association of individuals for the purpose of manufacturing wine. The term "farm" as used in this section includes all
of the land owned or leased by the farm winery licensee as long as such land is located in the Commonwealth.
(Code 1950, § 4-2; 1952, c.496; 1954,c.682; 1962,c. 533; 1970, cc. 302, 309; 1974, cc. 460, 497; 1975, c. 408;
1976, cc. 64, 702; 1977, c. 280; 1980, c. 324, §4-25.1; 1981,c. 410; 1984, cc. 200, 559; 1985, cc.448, 457; 1986, c.
190; 1990, cc. 300, 390, 707, 810, 932; 1991, c. 426; 1993,c. 866;2000, cc. 1037, 1052;2003, c. 631; 2008,c. 194.)
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