I object to and oppose this petition that would regulate a cost recovery method that has been ruled on, approved and implemented very recently, which would prohibit wholesalers from adopting pricing that enables them to recover the costs associated with fulfilling bottle business in Virginia.

A substantial cost for bottle versus cases processing include, but is not limited to -

1. Additional costly specialized equipment, box making material, box machine (to put the bottles in) additional warehouse space, software upgrades and breakage costs ( the more touches a product gets within the picking and delivery script, the breakage increases) are among the on site costs that we incur.
2. Nine Full time associates with full benefits are employed within the bottle station during the night's production.
3. Two more full time associates are responsible for restocking and maintaining the condition of this department during the day shift.
4. Additional driver time is needed to sort, stage and present individual bottles upon delivery to verify count and condition during receiving at retail/ restaurant. Each bottle product requires more  time at check in than a case of product.??

 Regulation 3 VAC5-30-90 allows for costs to be recovered  and these are true ADDITIONAL costs incurred. The decision to impose a split case charge should remain an individual wholesaler’s business decision.

As part of a multi-state family owned company, I can add that in the twenty-two states that RNDC operates in, this is and has been in place for years and is an accepted cost recovery method. I can also add that the largest wine producing an consumption state in the US,California,also utilizes a bottle charge.

Thank you for your consideration.

Sincerely,

Gary Archuleta

Exectutive Vice President

Republic National Distributing Company of Virginia