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Emissions from Aging Warehouses Do Not Significantly Contribute to Ozone Formation
  • 1990 Amendments to the Clean Air Act subjected distilled spirits to regulation by the Environmental Protection Agency (EPA). The EPA regulates beverage alcohol (ethanol) emissions as a volatile organic compound (VOC) - a compound which reacts in the atmosphere to form ozone.
  • Ethanol, however, is not very reactive and plays an insignificant role in ozone formation.
  • To meet the provisions of the Clean Air Act, "pollution" controls may be required for beverage alcohol emissions from distilled spirits aging warehouses despite that EPA has recognized that such controls could adversely affect product quality.
Changing Traditional Aging Practices Could Result in Unmarketable Products\
  • The aging process of distilled spirits is a natural one from which distilled spirits derive their fundamental characteristics, including color, taste and aroma.
  • Aging is an inherent and critical part of the production process. For example, "Bourbon whiskey", a distinctive product of the United States, is required by federal regulation to be aged at least two years in wooden barrels. The maturation process, which occurs over several years, involves natural oxidation that requires the passage of air and ethanol vapors into and out of the barrels in which products are aged.
  • Altering the aging process by imposing emission reduction technology on aging warehouses would affect the traditional maturation process for these products.
  • In its 1978 report concerning aging warehouses, the EPA recognized that control technologies could adversely affect product quality. To date, the distilled spirits industry is unaware of any similar EPA conclusion for any other industry where EPA performed a study on possible emission control technology and determined that the imposition of that technology could impact product quality.
  • With little to no environmental benefit, the economic cost to both the industry and the government would be unreasonably high if aging practices were required to be altered. Distillers would risk jeopardizing the quality and the very essence of their products.
  • Tax revenue for both federal and state governments would be threatened by any action which significantly impacts product quality and, thereby, sales.
Revise the 1990 Amendments to the Clean Air Act
  • Revise Section 302(s) of the 1990 Amendments to the Clean Air Act, 42 U.S.C., Section 7602(s), as follows: "The term 'VOC' means volatile organic compound, as defined by the Administrator; but shall not mean beverage alcohol (ethanol) compounds emitted from aging warehouses."

Distilled Spirits Council of the U.S., Inc.
September 1999


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