On September 17, 2026, I submitted the following public comment to the Alcohol and Tobacco Tax and Trade Bureau regarding the proposed Llano Uplift and Hickory Sands District American Viticultural Areas.
The comment grew out of research and reporting I had already been doing on the Llano Uplift and on the more narrowly defined Hickory Sands District. In addition to reviewing the federal petitions and supporting technical record, I had spoken with growers and winemakers working at vineyards within the proposed areas, including Perissos, Uplift Vineyard, Torr Na Lochs, and Robert Clay Vineyards.
I am publishing the comment here in full because it brings together some of the geological, climatic, groundwater, and vineyard-management evidence behind the proposals and illustrates how those physical differences are being experienced in working Texas vineyards.
Public Comment
Re: Notice No. 243 - Proposed Establishment of the Llano Uplift and Hickory Sands District American Viticultural Areas
Docket No. TTB-2026-0005
I support the establishment of both the proposed Llano Uplift and Hickory Sands District American Viticultural Areas.
I publish Explore Texas Wine, a publication focused on Texas vineyards, wines, and the people who grow and produce them. In reporting on the proposed Llano Uplift and Hickory Sands District AVAs, I have visited vineyards within the proposed Llano Uplift and spoken directly with growers and winemakers working in these areas.
My comments are directed primarily to the distinguishing geographic features of the proposed areas, their effects on viticulture, and the relationship between the proposed nested AVAs. Under 27 CFR section 9.12, an AVA petition must describe features affecting viticulture that make the proposed area distinctive and distinguish it from adjacent areas. For an AVA proposed within an existing AVA, the petition must also identify attributes shared with the parent AVA and explain why the proposed area is sufficiently distinct for separate recognition. Notice No. 243 specifically invites comment on both of those questions for these proposed AVAs.
Llano Uplift
The Llano Uplift petition advances geology, soils, climate, and groundwater as distinguishing features. Its geological and soil case is particularly significant. The distinction is not that granite exists only inside the proposed Llano Uplift or that limestone is absent from it. Rather, the petition describes many of the proposed AVA’s soils as derived from weathered granite and gneiss and states that its soils are slightly acidic, in contrast to the mostly alkaline, limestone-derived soils found in surrounding regions. Notice No. 243 summarizes the broader distinction as soils derived primarily from granite rather than limestone.
My reporting provides site-specific examples of how physical growing conditions operate in commercial vineyards within the proposed Llano Uplift but outside the proposed Hickory Sands District.
Perissos Vineyard and Winery, in Burnet County, is listed in the petition materials as within the proposed Llano Uplift but outside Hickory Sands. Dalton Humphreys of Perissos told me that the vineyard site was chosen intentionally for its decomposed-granite gravel soil. He described that soil as very low in organic matter, approximately neutral to slightly acidic, and extremely well drained, with a structure that allows roots to grow deeply and spread through the soil.
I offer that observation for its appropriate, limited purpose. One vineyard does not establish the character of a 2,096-square-mile AVA. Perissos does, however, provide a commercial-vineyard example outside Hickory Sands that is consistent with the petition’s broader evidence concerning granite-derived soils and their practical significance to vineyard siting and growing conditions.
Additional reporting from vineyards outside Hickory Sands illustrates how physical conditions within the proposed Llano Uplift can have direct viticultural consequences while varying from site to site. At Uplift Vineyard, winemaker Claire Richardson described intense heat, limited irrigation water, and small changes in slope that alter runoff enough to require different irrigation treatment within individual blocks. She described instances in which upper and lower portions of the same block are managed differently because of water movement across the site.
At Torr Na Lochs, Blake DeBerry described a higher site of decomposed granite and sand among exposed granite outcrops. In describing a late-March 2026 freeze, he reported that Torr Na Lochs experienced less severe and shorter-duration freezing conditions than nearby Perissos. He attributed the difference in part to cold-air drainage from the elevated site and heat retained by the exposed granite. I include that account only as a site-specific example of how local topography can affect vineyard conditions within the proposed Llano Uplift, not as evidence of an AVA-wide frost-protection advantage.
Together, these observations provide practical examples of how geology, topography, and water conditions within the proposed Llano Uplift can translate into vineyard-management consequences while varying from site to site. They do not establish the regional character of the proposed AVA; that broader case rests on the petition’s mapped geological, soil, climate, groundwater, and boundary evidence.
That geographic context is useful because Hickory Sands is proposed entirely within the northwest corner of the Llano Uplift, while Perissos, Uplift Vineyard, and Torr Na Lochs are commercial vineyards within the proposed parent AVA but outside Hickory Sands. The petition’s vineyard table identifies all three outside the proposed Hickory Sands boundary. The examples therefore provide site-specific evidence from outside the proposed nested district rather than asking the Hickory Sands evidence to carry the viticultural case for the larger Llano Uplift.
The Llano Uplift petition also identifies substantial characteristics shared with the existing Texas Hill Country AVA. Notice No. 243 describes both as having rolling hills, canyons, and valleys and notes that elevations within the proposed Llano Uplift fall within the range found in the existing Texas Hill Country AVA. The Hill Country’s soils also include granite- and sandstone-derived materials as well as limestone. The distinction advanced by the petition is therefore one of regional predominance rather than a complete geological or topographic break.
Those shared characteristics are relevant to TTB’s separate question of whether the proposed Llano Uplift, if established, should remain within the Texas Hill Country AVA. The petition’s distinguishing geology and soils support recognition of a more specific grape-growing region while its shared characteristics provide a basis for retaining it within the broader Texas Hill Country.
Hickory Sands District
The Hickory Sands District petition presents a more narrowly defined combination of soil, groundwater, climate, and elevation within the proposed Llano Uplift.
The petition describes elevations of approximately 1,500 to 1,980 feet, with an average commercial-vineyard elevation of 1,717 feet. To the east and southeast within the proposed Llano Uplift, the areas used in the petition’s comparison average approximately 983 feet. The significance of that difference is not that Hickory Sands is the highest terrain in the Texas Hill Country. Rather, the petition links its higher elevation to substantially greater nighttime cooling during the growing season.
Using PRISM climate data for 2018-2022, Exhibit 30 of the Hickory Sands petition reports average daily growing-season diurnal temperature swings of approximately 22 degrees F to 27 degrees F in Hickory Sands, compared with approximately 10.2 degrees F to 13.7 degrees F in the Llano Uplift comparison locations to the east and southeast. The calculations use daily differences between maximum and minimum temperatures during the April-August growing season, and the petition identifies elevation as an important contributor to the larger nighttime cooling effect.
That distinction exists despite very similar daytime heat. Exhibit 29 reports, for the 1991-2020 period, an average maximum temperature of 78.6 degrees F for the proposed Hickory Sands District and 79.1 degrees F for the compared Llano Uplift areas. The claimed climatic distinction therefore is not substantially cooler daytime conditions, but materially greater cooling after sunset.
Groundwater provides another quantified distinction. Notice No. 243 states that the petition identifies 66 irrigation wells yielding at least 200 gallons per minute within the proposed Hickory Sands District, compared with four in the portion of the proposed Llano Uplift outside Hickory Sands. The petition attributes the concentration of productive irrigation water primarily to the Hickory Aquifer and describes reliable irrigation water as particularly important under the region’s hot, dry growing conditions.
In separate reporting, Dan McLaughlin, owner of Robert Clay Vineyards and one of the Hickory Sands petitioners, described how these features operate together in vineyard practice. He described a combination of gravelly, iron-rich sandy soils, abundant high-quality groundwater from the Hickory Aquifer, vineyard elevations generally between 1,500 and 1,980 feet, and a materially greater day-night temperature swing during the growing season.
The Hickory Sands petition also identifies characteristics shared with the proposed Llano Uplift. Exhibit 29 shows similar maximum temperatures, vapor-pressure-deficit values, and dewpoints between the two proposed areas. Notice No. 243 likewise describes shared karst topography, exposed Precambrian and Cambrian formations, neutral-to-slightly-acidic sandy-loam soils over bedrock that includes granite, limestone, gneiss, and schist, and hot growing-season temperatures.
Those shared characteristics are important to the nesting question. The petition does not present Hickory Sands as an unrelated growing region. Rather, it argues that within a broader shared environment, the combination and degree of certain features – particularly Hickory Sands soils, productive groundwater, higher vineyard elevations, and larger diurnal temperature swings – are sufficiently different to justify more specific geographic recognition.
At the same time, the common geology, soil characteristics, landforms, and broader climatic conditions described in the petition provide a basis for retaining Hickory Sands within the proposed Llano Uplift. The same relationship supports retaining both proposed areas within the existing Texas Hill Country AVA. TTB has specifically invited comment on whether the proposed areas are sufficiently distinguishable for separate recognition and whether their geographic features are nevertheless sufficiently related for the proposed nested relationships to remain.
Conclusion
Based on the petition evidence and the vineyard reporting described above, I support establishment of the Llano Uplift as an AVA within the existing Texas Hill Country AVA.
My reporting at Perissos, Uplift Vineyard, and Torr Na Lochs provides site-specific commercial-vineyard examples outside Hickory Sands that are consistent with the petition’s broader evidence concerning the Llano Uplift’s physical growing environment and illustrate practical consequences for vineyard siting and management. These examples are corroborative; the regional case remains grounded in the petition’s broader geographic evidence.
I likewise support establishment of the Hickory Sands District as a more narrowly differentiated AVA within the proposed Llano Uplift and the existing Texas Hill Country AVA. The petition presents quantitative evidence concerning differences in soil prevalence and depth, groundwater availability, elevation, and nighttime cooling while also documenting geological, soil, and climatic attributes shared with the proposed Llano Uplift and the existing Texas Hill Country AVA.
For those reasons, I support establishment of both proposed AVAs, with the Llano Uplift remaining within the Texas Hill Country AVA and the Hickory Sands District remaining within both the proposed Llano Uplift and Texas Hill Country AVAs.
Don Huse
Founder & Writer
Explore Texas Wine

