I would ask VA ABC to amend its regulation regarding growler sales.  At this time a shop must have an on premise license to sell growlers off premise.  In my opinion this makes no sense.  A shop sells wine and beer off premise to customers so I don't understand the rationale for differentiating growlers.  A growler is 64 ounces of beer, less than a 6 pack of 12 ounce bottles.  I would argue that a customer would purchase this beer to enjoy at home instead of an individual drinking a pitcher of beer then driving home under the influence.  Revenue losses to restaurants and bars would be negligible but would really help a small gourmet shop owner's bottom line in this difficult economy.  One could argue that a growler has a screw cap which could be construed as easily accesible but many wines today have the same and bottled beer has an easy to remove cap.  Adults already know not to drink and drive so please do not punish the huge majority because some will get behind the wheel and drive under the influence.  The cost of selling food to meet the ABC on premise regulation is prohibitive to most small businesses.  The margin on a growler sale will help keep a small business owner up and running.  It will bring in tax revenue for the state, keep people employed and let craft beer aficinados happy while they enjoy their beverage at home.  Please amend the current regulation to let small gourmet shops that sell wine and beer to sell growlers off premise.  Thank you for your time and consideration.