The Virginia Beer Wholesalers Association fully supports the proposed amendments to 3VAC5-70-210 to increase the civil penalties for first-offence violations.  In particular, VBWA and its member wholesalers believe that the enhanced penalties for underage sale or possession provides the regulated community with renewed notice that the underage consumption of alcohol is not, and will not be tolerated.

The VWA has no substantive objection to the changes to the filing frequency and additional requirement of including package weight in the common carrier report.   However, for the record, at a time when margins are already very thin, we'd note that these increased requlatory requirements will come with additional costs, which will be passed on to the wineries and other suppliers utilizing the services of those common carriers.