Showing posts with label PLCB responses. Show all posts
Showing posts with label PLCB responses. Show all posts

Tuesday, March 22, 2011

Privatization as the 800 pound gorilla

The Morning Call's John Micek posted in his Capitol Ideas blog today about the PLCB's annual budget presentation to the Legislature, and noted that "...more than one lawmaker on the panel said they didn’t want to dwell on the potential privatization of the 70-year-old agency. But here’s the thing about 800-pound gorillas: They’re awfully hard to ignore."

Seems that the legislators said they didn't want to dwell on it, and then did just that, including this beautiful sentiment:
“I hear you saying that you want to be more like a private business. That begs the question of why not just privatize like 31 other states,” Appropriations Committee Chairman Jake Corman, R-Centre, told agency officials as they wrapped up their appearance.
Kinda reminds you of the PLCB's argument that their wine kiosks are soooo convenient...until you compare them to just picking a bottle off the shelf at the grocery store and putting in in the cart with your pork chops and eggplant.

Then came the "we'd be great if you'd just give us the freedom to really swing" plea from PJ Stapleton:

The board’s chairman, Patrick J. Stapleton, told lawmakers that the agency is seeking legislative remedies that would give it greater flexibility on pricing and hiring practices.
Right now, the agency is constrained in the discounts it can offer on certain products and civil service rules have hamstrung its ability to “put the right person in the right job,” Stapleton told legislators. [Of course, those civil service rules are mostly in place to prevent rampant patronage; why's the PLCB so hot to circumvent them?]
“We’ve endeavored to create a world-class business operation,” he said. “Unfortunately, we’re limited in certain respects by [state law].”

Call me crazy, but I have a strong feeling that it would be much easier to simply do away with The State Store System than to tweak hell out of The Almighty Liquor Code to allow "a world-class business operation." But if you don't believe me, here's the PLCB's 'secret plan' to fix things so we'll never ever see privatization rear its ugly head again. Please note the bond issue, which would borrow against the next 20 years of PLCB "profits" to blow a chunk of bucks into the state's budget now...effectively guaranteeing that no legislator would bring up privatization for 20 years, because then they'd have to pay off the bond: brilliant!

Why is the State Store System so resilient, why does it still hang on? 

  • The unionized staff comes out en masse against privatization, always has (and brags about it), and is joined by their union brothers and sisters. They're just getting warmed up this time around.
  • The personally offensive state monopoly (you're not allowed to buy booze anywhere else and bring it into PA) is a lot easier to maintain with a state system.
  • It brings in a buncha bucks, because the state's Leaning Tower of Booze Taxes is so much more oppressive than in other states (tip of the hat to PLCB Users Group creator Nathan Lutchansky for pointing that out (not, of course, in the form of a "diatribe," like I do here) and actually doing a better job than I did: turns out I missed some charges), and the PLCB and the union have done a fantastic job in convincing you that they bring in all that money, when it's really the state's tax laws that bring in most of it...and would continue to do so in a private system.
  • People (voters) still believe that it's actually effective in making the state safer, despite evidence to the contrary; hell, the PLCB's own bi-annual report admits that PA is not really that different from other states in negative drinking issues. 
This is our best shot in years. Don't blow it. This is not about Wisconsin, this is not union-busting, this is not about Republicans vs. Democrats. This is about a patronizing system of state control, a Stalinist system of government-owned retail that never should have started, and should have died a relatively natural death decades ago. It's a zombie, and it's long past time to shoot it in the head.

Monday, October 26, 2009

"...bringing any alcoholic beverage into Pennsylvania is illegal..."

Well, I got my response. I recently wrote to the PLCB to ask them how a private citizen, who happened to be in another state and saw a nice bottle of wine for sale, and wanted to bring that bottle home to Pennsylvania, could do their duty to the Commonwealth, fill out a form, pay the taxes, or so on. How could we do the right thing in order to bring this into the State and be square, in other words?

After two weeks -- a relatively short time, considering it came from the PLCB's chief legal counsel -- I got my response this morning. I'd publish it here, only it came by e-mail in the form of a PDF image, which has so far resisted four different attempts to convert it to text. No problem; I've successfully uploaded it to Scribd, and you can see it below.

Please note, before we go any further, that they took pains to note that the State Police Bureau of Liquor Control Enforcement enforces the liquor laws, and the PLCB issues legal opinions that are binding on licensees only. "Since you are not a Board licensee, the following is offered for your guidance and information only." Ah. Kinda like the fine print on the video poker machines that Pennsylvania seems completely unable to stamp out. Okay. With that said, let's see what their opinion is.

The third paragraph puts it pretty damned simply: "The general rule is that bringing any alcoholic beverage into Pennsylvania is illegal, with limited exceptions." You have to be "the Board, a manufacturer, or the holder of a sacramental wine license or of an importer license" to transport or possess any liquor or wine within the Commonwealth that has not been purchased from the State Store System or a state winery. "Accordingly, you cannot simply cross the border into a neighboring state, purchase a bottle of wine and return to Pennsylvania, as both the importation and possession of such wine would be illegal."

However...turns out that you can bring in up to one gallon free of tax and mark-up...from outside the United States. So, New Zealand is okay; New Jersey, no way. And if the Board requests it, you have to produce evidence of such travel, the receipt proving you actually bought the stuff there (and not, for example, in New Jersey), and "an affidavit indicating that the purchaser was allowed to bring the liquor in duty-free" (no instructions on who would issue such an affadavit...). And before you think this completely painless, "The Board assesses a service charge for this importation." Of course they do.

You can receive wine and liquor from outside the Commonwealth as a gift, "so long as the proper paperwork is submitted to and cleared by the Board." And you pay the service charges and mark-up, and by the way, you have to pay the taxes to the Department of Revenue, so you have to talk to them, too.

Feeling like Kafka yet? Remember that you do have the ability to purchase wine from outside the Commonwealth! You may purchase it online! And then have it shipped to one of the State Store System's stores (of your choosing!). There are a few conditions, of course: the wine cannot be one listed on the Board's Internet catalog; you'll have to sign an affidavit that you are 21 and purchasing the wine for your own "use;" and you can't get more than 9 liters in a month. Oh, and there's a shipping charge, a handling charge, the 18% Johnstown Flood Emergency Tax, and 6% sales tax (plus an additional 1% in Philadelphia or 2% in Allegheny County). Bet they get a lot of traffic on that one.

In short, they conclude, "...there is no proper protocol for crossing the border to purchase wine in another state and then bring it back to Pennsylvania." And that's pretty much it.

(The letter was copied to the Bureau of Liquor Control Enforcement, to the Senior Director of the Office of Regulatory Affairs, the Director and Assistant Director of the Bureau of Licensing, and the Press Secretary. I'm not intimidated, I refuse to be.)

The beautiful thing is, they don't have to provide a proper protocol, or the reasoning for why that is not allowed. That's the responsibility of the Legislature, by way of The Almighty Liquor Code. Why is it that way? Because the State Store System and the PLCB were set up to be a total monopoly -- it's the Pennsylvania Liquore CONTROL Board, after all -- and you can't have a monopoly that leaks around the edges.

Oh, it does, of course; people bring booze into the State every day. You know it, I know it, the Bureau of Liquor Control Enforcement, everyone knows it -- except the PLCB, apparently, as Joe "CEO" Conti continues to hold that this is a very minor problem. Sure it is. Which is why there are all those big liquor stores so close to the border in Delaware and Maryland, and why the out-of-state liquor stores run full-page ads in the Inquirer.

I am deeply offended by the very idea of this monopoly. I drive to visit my in-laws in New York and Virginia several times a year. I'm an American. What right does the State of Pennsylvania have to tell me where I can or cannot buy a bottle of liquor? If it's all about the taxes, why not make it easy for me to pay the damned things? No, instead, we're told that "bringing any alcoholic beverage into Pennsylvania is illegal." That's asinine!

Let me make this perfectly clear. I deeply appreciate the time that the lawyers at the PLCB took to write this response. I do; I have no doubt they know who I am and why I wanted to know, this site gets hits from the PLCB multiple times a week, but they responded, and they didn't mince words. I don't hold the PLCB or the BLCE responsible for this ridiculous situation.

I blame The Almighty Liquor Code and the Pennsylvania Legislature. For 75 years we have been under the patronizing thumb of this monopoly. We have no choice except theirs, we have no options but theirs, we have no way to change it or make it better. This is not the fault of the PLCB. Rather, the PLCB and all it stands for -- monopoly, conflict of interest, political patronage, lack of choice, lack of response -- is the fault of the continuing refusal of the Pennsylvania Legislature to lift this Stalinist, paternalistic, antiquated system from our shoulders. It's 2009: could we be allowed to buy a bottle of wine wherever we want? Is that so much to ask? Or do you vant to see our papers?

Read the full text of the PLCB's response on Scribd here

Tuesday, March 17, 2009

The Conti and PJ Show!

I watched the PCN Call-In with Joe "CEO" Conti and PJ Stapleton tonight. It just wound up, and here's what I took down. I'm scrambling and trying to remember, so I may not have who said what exactly correct, but the gist is here.

Host Brian Lockman (who interviewed me on PA Books, nice guy) went right at them with questions about the courtesy contract. Stapleton first said that the training is "desperately needed" for the employees to perform their jobs. "Desperately?" Really? This is the guy who said training on 'manners' would be ridiculous and unnecessary, because "our employees already are widely regarded as being welcoming and polite to our customers." Of course, he stuck to the line that it wasn't really about manners, even though the first priority of the tasking in the RFP is to "Improve basic customer service skills."

Not sure if it was here, but at one point Stapleton started talking about how the training is also about not serving underage or intoxicated people and said "If it saves one life, that's worth the price." God! I'm looking right at the RFP, the whole list of what this training is supposed to accomplish, and there's not one word about that. The only thing that even comes close is the last one, a catch-all: "Encourage engagement with the PLCB's current agency-wide initiatives; instilling a desire and ability to support these initiatives in interactions with customers and in merchandising techniques." Yet Stapleton made it sound like there would be specific training to save the children. Truly pathetic.

Lockman asks Conti about the possible problems with the awarding of the contract to Solutions 21, in light of the president of the company's wife being a high-ranking PLCB regional manager. Conti says they knew of the issue with the contract, ran it past counsel, and decided it was legal under the state's rules. Interestingly, he wound up by saying that the rules may need to be changed by the Legislature. Indeed. PJ says he feels strongly they made the right decision on the contract, cites the cost. No one questions why it's so low. Bummer.

Lockman asks if the RFP was put out and awarded too fast, as has been suggested by two of the losing bidders? Conti says not, really. PJ says it's standard stuff, and it is, and RFPs go out fast. It's not like teaching someone basic retail -- customer skills, conflict resolution, "embracing organizational change" -- is something earth-shatteringly new. Well...except for the PLCB employees who desperately need it, according to Stapleton. We'll see why in a bit.

Lockman asks Conti, so what have you been doing in two years? Essentially, he's been planning for two years. Strategic store initiatives, new look, new stores, new websites. You know, all that stuff they don't really need to do because they're a monopoly." We will be the specialty retailer we always should have been." Yeesh.

Lockman tosses Conti the cost softball: why are prices higher in the State Stores. Conti rips it up and tosses it aside, saying they aren't higher, except compared to Delaware, and that's because they don't have taxes, those naughty boys. No one ever mentions how well that seems to work for Delaware and the business it attracts. Lockman asks him if the Johnstown Flood tax is really for the Flood. No skin off their nose, that's the Legislature's fault. "The tax is a remnant." Conti dangles the possibility of lowering the Johnstown tax if more sales come in. (But isn't that The Legislature's call?) They repeatedly talk about how much the PLCB "brings in" without ever mentioning that 75% of it is taxes that would be collected anyway under privatization.

Lockman asks what's the Board do, what's Conti do? Stapleton babbles a bit, says the Board makes decisions, and "has the assistance" of Conti. Conti runs day-to-day operations. I guess he does, except when he's planning for two years. He admits the PLCB is a "Prohibition era bureaucracy." Then he dangles more money in front of us: "We want to provide revenues to the general fund so other taxes can be reduced." Oooo! Sure, that could happen, and if it does it would likely be the first time in the history of the state.

Lockman asks, is there a built-in conflict in the agency's two missions? Stapleton says that the stores provide customer service and encouragement for responsible use. "We 'control' the responsible use of alcohol." Wow.

Finally, the first call, from Narberth, I think, and it's the Jose Garces question. Two questions: What's the goal? And what's PLCB going to do to ensure it's fair to other restaurants? The initial concept is to provide a boutique wine experience, wines that aren't available in the stores. "We will be a tenant of his." No liquor served. 600 sq. ft. area next to it. Match and pair wines with foods. It's important to team with Jose Garces, because he's cool and respected. And then, no surprise whatsoever, he completely ducks the fairness question. Nicely done, Chairman Stapleton. The second-hardest question of the evening, and he deftly avoided addressing it. No follow-up.

Conti fields a question from Lockman: what about these wine kiosks. It's ongoing, God help me. "Very interesting." They're going to be using biometrics to determine your age and intoxication! It's 12 - 18 months away from getting out there. Lockman asks, Are the machines more secure than a clerk? Yes, Conti says. Even after this amazing training? Biometric technology to ensure 21 and not intoxicated. "Incredible technology." I'll bet. They will be testing the machines. Moving forward. They could be used in the stores.

Next call: A suck up, just as predicted. Doing a great job, great wines, used to shop elsewhere. The contract: there's always room for improvement. Wow. Amazing. Do you think there will be any calls like this on tomorrow's show with the Attorney General? Hey, AG, great job you're doing putting away those criminals!

Third call: weirdly pissed off person who wants to know how many other contracts on training they've let in the past year? Um, none. Just this one. Even I knew that one.

Lockman asks about selling beer at Wegmans. Had to be asked, but it's a waste of time: they're just administering the Liquor Code. The Wegmans are licensed establishments. Yada yada.

Next call: free drinks at casinos are not a fair playing field for taverns. It is a pure legislative manner, says Conti, and he's absolutely right.

Next call: why are we spending this money? We don't have a choice to go to some other place! People are sick and tired of waste. Yeah, and he was angry. I'm just sick and tired of not having another place to go to.

Next call: just angry. I'm cool with that, because, after all, these guys are not going to make any mistakes that might result in answering a question.

Next call: is there any patronage on the wine kiosk contract, anything that might benefit anyone related to someone at the PLCB, or the Governor's Office? (Does this guy know something?) Conti ducks it by saying it followed the same track as the courtesy contract, a track that he already questioned the effectiveness of, but said it was legal. Okay...so you heard it here: Conti is implying that there is no questionable connection between the PLCB or the Governor's office and Simple Brands LP, James Lesser president, of Bala Cynwyd, the only bidder on the contract, according to news stories on this project.

This one smells funny. This is a big, tech-heavy, expensive project. Yet Simple Brands has no website, no web presence at all that I can find, which seems kind of odd for a company bidding on such a technology-heavy project. Anyone ever heard of Simple Brands, or James Lesser? Who's he married to? Who's he know? He was formerly the head of JDL Management, and made retro-fitted Skeeball games with red balls with flashing lights. Great. If you're curious, the contract is here; you can see the RFP and the contract by clicking on the successive PDF links.

Next call: Stapleton and Conti essentially admitted that they hire employees with no real experience or training. Good God. They blame the civil service system they're stuck with. Stapleton says that the future includes "A formal PLCB training academy." Really, he said that. Can't wait to see the bill on that one.

Lockman asks: why are State Store employees paid so much more than clerks in liquor stores in other states? (And they are, I've seen the same report he mentions.) Stapleton appears surprised by this, takes moral high ground by saying they're not ashamed of paying the clerks a living wage. I don't recall Lockman saying that the other clerks were poor, just that the State Store employees were paid a lot more than other retail clerks. Yet on the last question, Stapleton admitted that these were inexperienced employees.

Lockman ask, before Conti was hired, was Chairman was highest position at LCB? No, says Stapleton. The Board is responsible for decision-making. Ah. "Decision-making." That's not important. He says there was no office to oversee all the departments, someone to distill all the info and requests. It's an antiquated system. Yet, Lockman asks, you functioned for years without a CEO, who is now paid 2.5 times chairman salary. Stapleton says the chairman was not running the shop. Who the hell was? And they're about to add three new executives. Wonder what their salaries are.

We get another suck-up call. You're doing a great job and I don't want to stand beside drunks in the grocery stores, thank you, thank you. So...anyone buying off-premise beer is a drunk? But the people who buy off-premise wine and spirits at State Stores aren't? What a fraud call.

I finally get through, and while I'm waiting, I hear someone on the phone asking my question: if things are so good, why are all those stores on the border? They tap dance. The prices aren't really that good, they're only better right at the border, you go ten miles into New Jersey and the prices go up. (So what? I'm not going to go ten miles in Jersey then, am I?) Selection? Those stores don't really have a better selection -- a brazen lie, I'll happily take him to Total Wine and make him eat it if someone can get him to go -- but they're very good at talking you into buying something else. Not just a lie, but nasty.

They said over and over again that the State Stores had such a great selection and served the state so well. Horsecrap. I don't know how they can possibly serve the state that well when the number of stores is about 1/3 the number states of similar size have, and the 'great selection' is all online and special order, many of which you have to buy multiple bottles of. That's not a great selection, that's an annoyance. When they had their little temporary kiosk at the Pennsylvania Whisky Festival, back in November, they didn't even have all the brands available at the festival: you had to special order stuff they knew was going to be there! Ridiculous to compare that to a fully-stocked liquor store.

So when I got on, I asked, look, I see a lot of PA plates in those cross-border stores. Do we know how much in sales and taxes we're losing in cross-border bleed? If it's so great here, why do people go there? They quoted a study they had done -- love to see a copy -- that showed that very few of such trips were 'destination' trips; people weren't going there just to buy booze. And that they still bought 75% of their booze in PA. And they were only losing 3-4% to cross-border bleed. Burying me in numbers that mean nothing if I can't see the methodology.

You know what? I know someone who crosses the border just to buy box wine. They save a few bucks on each box, so they get two or three whenever they go to Maryland. That's not a destination trip, but it's definitely part of the trip. I can't help looking at the concentration of stores across the border and wondering: if there's not much to be made in luring Pennsylvanians across the border, why are those stores there, and why do they continue to run full-page ads in the Inquirer?

And that was it. No surprises. No revelations. No real answers. And some really misleading stuff. I was very sorry no retailers called in...but I'm not surprised.

PLCB's 'CEO' Conti and Chairman Stapleton on PCN Call-In tonight

Got questions about the PLCB? Want to know why your favorite wine (or bourbon, Sam) has disappeared? Curious about SLO? Jealous of the towns that have beer sales at their Wegmans or Sheetz? Can't figure out why we have the case law, or why beer is sold in private stores but not wine and liquor? Want to know why the PLCB is training their clerks to be polite? Want to ask Joe 'CEO' Conti just what it is he does? Would you like to hear them defend their very existence?

Itch for knowledge no longer. Both 'CEO' Conti and PLCB Chairman PJ Stapleton will be on PCN-TV tonight on the Call-In show for an hour, at 7 PM. I'd urge you to watch this. If you do call in a question, please be civil. I'd hate to have Chuck Ardo think you were criticizing them for curing cancer.

This should be fun.

Tuesday, March 10, 2009

More People Upset by the PLCB's Latest Off-Pitch Idiocy

It's not just me that thinks the PLCB is crazy, stupid, and wasteful spending $173,000 of Pennsylvania taxpayers' money (in a budget crisis...) on teaching PLCB clerks to say 'hello' and 'thank you' (I hope they're not training them to say "Have a nice day!"). Check out this from the Chambersburg Public Opinion:

But let us take our own stab at it.
Pennsylvania liquor store employees: When conducting transactions and serving customers during your work hours, be solicitous and respectful, smile, and always say please and thank you.
There! We just fulfilled the fundamental intent of this insane PLCB endeavor, and it cost you less than a buck.
Much obliged.

NBC affiliate WCAU/Channel 10 in Philadelphia had a proper response, and pointed out that Philadelphia's Department of Licenses & Inspections, another agency with a bad customer service reputation, was getting free customer service training, courtesy of the Ritz-Carlton Hotel in town.

Shameful.
Not only are you (the taxpayer) footing the $175,000 bill for a better experience at your local liquor store in Pennsylvania. Guess who gets that money? Turns out you're padding the pockets of a man who is married to one of the Liquor Control Board's top-level employees, according to the Inky. How convenient.
But there's no conflict.
Suuuuure there isn't!

The Lehigh Valley Express-Times was quite a bit more blunt about the whole thing:

Pennsylvania's antiquated system for selling booze and wine has been out of date for decades. But don't look for the state to give up the cash-cow system and its cache of patronage jobs anytime soon.
Maybe the powerful bureaucrats can teach their brothers-in-law how to say hello and thank you before they get the job.
It would save us all a few bucks.
Ouch!

But the PLCB -- and the lucky Buddy Hobart of Solutions 21 -- knew people might be skeptical (at least, skeptical of the program; looks like the whole nepotism thing caught them off-guard). From the initial story:

"What I say to the skeptical," said Buddy Hobart, president of Solutions 21, "to those of us in the world who believe we've arrived and don't need to improve: Look up the word arrogant in the dictionary."
Added the LCB's Conti: "This is a vast adventure, and it's one we have to take. We know some people will critique us, but we like that. It only makes us better."
Hello? What I say to the Buddy is that it's all about the money his firm is getting paid for these truly questionable services. Because no one on earth believes that the PLCB has "arrived" or doesn't need to improve. Actually, that's not quite true; as I've said before, I don't want the PLCB to improve, I want them to go away.

And Conti? "A vast adventure"? "We like that. It only makes us better"? Please! Spare me the happy talk. Learning to say "Please" and "Thank you" is not a vast adventure.

What you should be doing is creating a divestiture plan, a plan to make the most possible money for the State by dismantling the State Store System, selling off its assets, setting up a new licensing system for private liquor stores that will actually benefit the State instead of the store owners, and minimizing the impact on the PLCB clerks and the costs of privatization.

That would be a vast adventure worth taking.

Wednesday, June 25, 2008

Growlers: a response from the PLCB

I asked the PLCB about growler regs for a newspaper piece I'm working up, and I got a response this morning. My thanks to Ms. Chapman for a thorough response with a minimum of bull...and I gotta figure the PLCB knows about the blog: my tracking software has registered multiple daily visits from a PLCB computer since about the third week the blog was up. Cheers to the fairness, which is why I have tried to be as fair as possible myself.

Here's the response; I've bolded some interesting bits, (and added some comments and "interpretation"):


Lew,

Your query on growlers was passed on to the PLCB press office. It seems plausible that everyone you ask might have a different idea of the law, because there are different restrictions on beer sales depending on the type of licensee selling the beer.

There is no specific language in the Code addressing growler packaging . In many cases the customer provides the actual container, whether it is a growler he's purchased from the brewery, or something else. (This would certainly seem to indicate that the PLCB doesn't care what growler a brewpub fills, or what the label says, or whether it's sealed.) All the language concerns the maximum or minimum amount of beer that a customer may take off the premises.

Here's a summary of what is in the Code concerning take-away draft beer, and the actual code:

Brewpub licensees, MAXIMUM of 192 ounces. These are establishments that serve food and beer on the premises, and sell for off-premise consumption. They have the same take-away limits as restaurant, hotel and eating-place licensees. (Note that this seems to imply that growler sales by restaurant, hotel, and 'eating-place' licensees are legal. No problem there.)

[Relevant code: SECTION 4-442. Retail dispensers' restrictions on purchases and sales

(a)(1) No retail dispenser shall purchase or receive any malt or brewed beverages except in original containers as prepared for the market by the manufacturer at the place of manufacture. The retail dispenser may thereafter break the bulk upon the licensed premises and sell or dispense the same for consumption on or off the premises so licensed: Provided, however, That no retail dispenser may sell malt or brewed beverages for consumption off the premises in quantities in excess of one hundred ninety-two fluid ounces: Provided, further, That no club licensee may sell any malt or brewed beverages for consumption off the premises where sold or to persons not members of the club.]

Brewery licensees, MINIMUM of 64 ounces. These licensees only brew beer and only sell for off-premise consumption.

[Relevant code:SECTION 4-440. Sales by manufacturers of malt or brewed beverages; minimum quantities

No manufacturer shall sell any malt or brewed beverages for consumption on the premises where sold, nor sell or deliver any such malt or brewed beverages in other than original containers approved as to capacity by the board, nor in quantities of less than a case or original containers containing sixty-four ounces or more which may be sold separately; nor shall any manufacturer maintain or operate within the Commonwealth any place or places other than the place or places covered by his or its license where malt or brewed beverages are sold or where orders are taken.]

FYI, this 64-oz. minimum is a result of Act 15 of 2003, actually passed specifically to reduce the minimum from 128 oz. and permit growler sales at breweries . (Note that this means half-gallon and two-liter growlers are legal at all retail locations; and explains why Weyerbacher was selling gallon growlers; they did it before the 2003 rule change. Anyone still have one of those gallon growlers?)

The only other thing to keep in mind is that local municipalities may have open-container laws that could restrict growler sales. (Which begs the question...is a growler an "open" container?)

I know you're familiar with the law governing non-growler sales:

Beer distributor, MINIMUM of 128 ounces (kegs, cases). Off-premise sales only.

Restaurant or eating place licensee, MAXIMUM of 192 ounces. (Two six-packs to go.)

If you want to peruse the whole Liquor Code, you can find it online at http://www.lcb.state.pa.us/plcb/cwp/view.asp?a=1334&Q=546255&plcbNav=3236632398

Please don't hesitate to call us directly if you need anything else.

Francesca

Francesca Chapman Deputy Press Secretary