Ninety per cent of BC wine is purchased in BC, but the industry's main marketing goal is to diversify sales across Canada and gain recognition in markets around the world. An important tool in gaining recognition for the quality and distinctiveness of BC wine is the identification of sub-regions, or sub-Geographic Indications (sub-GI). Sub-regions draw lines around distinctive geographic, geologic, climatic and, to some extent, cultural zones, giving them a name, and saying “this is here” - terroir expressed in practices inscribed in regulation.
The question is, are the new sub-GIs actually justified?
Establishing the sub-GI Regime
The criteria for creating wine sub-regions in British Columbia were set out by the BC Wine Authority in creating the Golden Mile sub-GI. These have guided the research, analysis, and recommendations for subsequent sub-GI applications.
They inscribe the boundaries of a geographically distinct zone in which there is a commercially-viable volume of production and in which two-thirds of producers producing two-thirds of the wine vote to endorse creation of the sub-GI. The rules establish that 95 per cent of the juice in a wine labelled with a sub-GI must come from vines grown within that sub-GI.
What does “distinctive” mean with regard to terroir? The BCWA recognizes that while geography, geology, and climate conditions are shared widely, certain features make local spaces distinct from their adjacent neighbours and from the wider GI of which they are a part. It is around these distinct spaces that lines are drawn, names attached, and labelling rights granted. Drawing lines creates insiders and outsiders, and this process was politically sensitive in creation of the Golden Mile appellation.
Crucially, says the BCWA, “Wines produced in a proposed sub-GI must consistently demonstrate distinctive characteristics related to the shared soil, topography and climate, enhanced by the adoption of specific production practices.” The assumption here is that “geographic differences can result in subtle differences in growing conditions, which in turn affect flavour profiles in grapes and potentially produce organoleptically distinct wines.”
The distinctiveness of wine from a sub-GI is to be judged, not in comparison with wines in other sub-GIs, but those produced in the wider GI (for example, the Golden Mile versus the Okanagan Valley). Surprisingly, there is no requirement that proponents of a sub-GI prove by “objective chemical and sensory analysis” that wines from the zone demonstrate the distinctive characters as claimed, directly as resulting from geographic conditions, “although the Authority expects that this will usually be the case.”
The BCWA also says zones with a sub-GI designation cannot be claimed as superior for grape-growing or wine-making in comparison with others. “Distinct in this context simply means ‘different’, say the guidelines. “It does not mean 'better'.”
How will the sub-GI over time affect the variety of production within the sub-GI? The BCWA notes that to “require proponents to demonstrate that all varieties grown within the proposed sub-GI display a similar level of distinctiveness is, in the Authority's view, simply far too onerous and unrealistic a standard in the circumstances.” However, the BCWA will expect proponents to “demonstrate distinctiveness related to at least a significant proportion of overall production within the proposed sub-GI.”
The sub-GI rules may therefore provide an inducement, over time, to narrow the range of varietals grown in the sub-GI. If producers in a sub-GI are to meet the “significant proportion” test (20-40 per cent of production) and retain the sub-GI over time, the range of varieties grown in the region may have to narrow in order to demonstrate that uniqueness.
There are many variables, beyond soil, topography and climate that affect the distinctive character of wine produced within a defined zone. Does the BCWA think sub-GI rules should mandate certain production practices in the vineyard and the winery? Apparently, as they state, “Proponents must provide some evidence that specific production practices are being utilized to enhance distinctiveness.”
The Rules in Practice
The BCWA says a test run with Merlot wines gave it confidence to go ahead with the sub-GI regime and, convinced that local conditions can produce distinct wines, the BCWA was satisfied the framework could be applied to further sub-GI applications.
Sub-GIs have been created in BC for the Golden Mile (2014), Naramata (2018), Okanagan Falls (2018), Skaha Bench (2019), and Comox Valley (pending).
The least-persuasive of the sub-GIs is Naramata, because it embraces at least two quite distinct landscapes, soil and climate sectors, above and below Naramata Road. Below the road is glacio-lacustrine bluffs, wells, and gullies which have “unique characteristics” and stone-free silty clay loam. Above the road are various mixed soils and topography with “no one dominant soil type” and gravelly sub-soils.
There is also a wide variation in climate, as the sub-GI extends from 400 metres up to 700 metres in elevation, so the “combination of dominant slope, topography, and landscape position creates a range of mesoclimates within the sub-GI.”
Conclusion
The consultants' reports upon which the BCWA's recommendation are based find distinctiveness, if not uniqueness, in the sub-GI zones, but the diversity of physical conditions described within the zones remains significant, to say nothing of production practices. Wines labelled as sub-GI should, over time, converge towards a distinctive style, but diversity in site and production practices suggest this convergence may remain elusive.
Second, how much of an advance is it to give regulatory legitimacy to the goal that a sub-GI Chardonnay is distinct from a GI Chardonnay? The goal should be distinctness from one sub-GI to another. Benjamin Lewin MW says of California Chardonnay, “The style is at its fullest in Napa, similar but a little less rich in Carneros, somewhat leaner in Sonoma, with Russian River Valley providing a more elegant style” [Wine Myths and Reality, Vendange Press, 2010, p. 167]. The comparison here is not Carneros and California, but Carneros and its neighbours. This should be the ambition of a sub-GI regime which intends to attract serious recognition: that a reasonable taster should be able to detect the distinctiveness of wines produced in other sub-GIs.
A more fundamental question arises from doubts consistently raised about wine quality and character as expressive of the soil in which the vines are grown. Of all the variables at play, geology may be least influential. “Most of what we taste in wine is produced during vinification. This is what primarily sets wines apart, not what the roots absorb,” says Alex Maltman in the book Vineyards, Rocks and Soils. If so, this calls for production practices to become a more important criteria of sub-GI definition.
Does the BC Wine Authority have the institutional capacity to ensure the ongoing empirical verification of the (even slim) requirements of the regime so far? Current VQA rules prohibit sensory tasting panels from failing a wine because it deviates from expected varietal typicity. Will “distinctiveness” be subject to sensory panel adjudication?
Wineries need to be clear about what they expect from sub-GI identities. Will wineries seek to make more demanding the requirements of production practices for wines with sub-GI labels? Will wineries narrow their range of varieties planted to meet expectations of distinctiveness in the sub-GI?
The fundamental weakness of the sub-GI regime is that it promotes distinction without meaningful difference. The weakness of the production practices criteria means that factors unique to the wineries, not place, will dominate the sensory profiles of wine quality and character.
The sub-GI regime is indicative of a young industry maturing, and the thirtieth anniversary of the BC VQA regime in 2020 is an important milestone. In creating the sub-GIs the goal was to facilitate, to provide the incentive, for wineries to aspire to sub-GI distinctiveness. Now that the sub-GI criteria have been established, the ongoing test is whether they provide the incentives, and the disciplines, for producers, regulators, and marketers to do the work necessary to discover and define the identities of the locales that they claim to have begun to explore. Otherwise, consumers will see it as a flimsy, crude and cynical marketing ploy – to the extent they see it at all.
Ernie Keenes is a retired journalist and political scientist with an ongoing interest in the policy and regulatory aspects of the BC wine trade. He works in wine retail in Kelowna, and is a partner in a small and strictly non-commercial vineyard and winery in West Kelowna. [Readers can find expert reports of the similarities and differences amongst the sub-GI zones on the BCWA web site.]