Increasing the dollar amount of giveaways from $10 to $20 wholesale - the increased value of $20 wholesale exceeds a reasonable limit for a "novelty" and may be considered an expensive incentive to buy the alcohol brand promoted. I am concerned that these items can be distributed at athletic events which are often attended by youth.

Allowing contributions of alcohol to charitable events - if alcohol served must be purchased by the charity, less alcohol will be served than if they get it for free. I am also concerned that carding at these events may not be well controlled with untrained alcohol servers and and it is difficult to be aware of the age of the drink recipients at a charitable event.

I oppose the recommendation to allow coupons on alcoholic beverages. Research has repeatedly shown that one of the only things that decreased overall alcohol consumption is price increase. To allow citizens to use coupons would go against everything the research suggests to reduce drinking, especially among college students who regularly consume at a high-risk level and drink to get drunk.

Studies show that when the price of alcohol increases, there are reductions in motor vehicle crashes and fatalities, alcohol-impaired driving, violence and deaths.  Alcohol consumption increases when the price is lowered and this is particularly true for youths. Do not lower the price of alcohol by allowing manufacturer coupons.

Do not allow instantly redeemable manufacturer coupons. Alcohol consumption is responsive to price. Studies showed higher alcohol prices were consistent with fewer motor vehicle crashes and fatalities, less alcohol-impaired driving, less violence and fewer deaths. Youth are particularly sensitive to price. Do not lower the price of alcohol by allowing manufacturer coupons.

Research consistently demonstrates that as alcohol price goes down, harm goes up, and cost to society increases. Underage youth are those MOST sensitive to price reductions and they are also those who are the savviest about using the internet.

Everyone knows, and the data proves, that when the cost of a product goes down, more people will buy it. This certainly applies to alcohol, especially when we're talking about young people. Discount coupons reduce the cost of alcohol, thus encouraging people to drink more. Why, when we already have a horrible problem with alcohol abuse and binge drinking would we want to encourage people to drink more. It's dangerous and it costs private business and the state millions of dollars each year to address the problems created by problem drinking. Please don't allow couponing.  

I oppose the recommendation to allow instantly redeemable coupons to reduce the price of alcoholic beverages. Research has repeatedly shown pricing has great elasticity relative to alcohol consumption. As prices for alcohol increase youthconsumption goes down especially among youth and problem drinkers. When the price goes down, consumption goes up. In other countries, happy hour and other price reduction strategies have been linked specifically to binge drinking and drunk driving. To allow citizens to use coupons to buy less expensive alcohol would go against everything the research suggests to reduce drinking, especially among college students who regularly consume at a high-risk level and drink to get drunk..

Instnatly redeemable manufacturer coupons mean cheaper alcohol. Cheaper alcohol means greater alcohol consumption. Lowering the price of alcohol through manufacturer coupons will increase alcohol-related harm, such as motor vehicle crashes, violence, injuries and death. Please do not permit manufacturers to issue coupons.

Research has shown that alcohol is responsive to price.  As the price goes up, consumption goes down.  When prices go up there are also less traffic crashes, DWIs, rapes and robberies, suicide and long-term health consequences.  Decreasing the cost of alcohol with redeemable coupons will decrease public safety and well-being.

Do not allow instantly redeemable manufacturer coupons. Alcohol consumption is responsive to price.  Studies showed higher alcohol prices were consistent with fewer motor vehicle crashes and fatalities, less alcohol-impaired driving,  less violence and fewer deaths.  Youth are particularly sensitive to price. Do not lower the price of alcohol by allowing manufacturer coupons

The Task Force on Community Preventive Services conducted a systematic review of scientific literature and determined that alcohol consumption is responsive to price.  As price goes up, alcohol consumption goes down. On average, alcohol consumption decreased almost 8% as price increased 10%. As consumption of alcohol decreased, so did alcohol-related harm. Higher alcohol prices were consistent with fewer motor vehicle crashes and fatalities, less alcohol-impaired driving, less violence and fewer deaths.  Some studies showed that youth (both underage and college age youth) were particularly sensitive to price of alcohol.  Higher alcohol prices were associated with less youth drinking.

 Due to this relationship between alcohol, price and related harm, we are very concerned about lowering alcohol prices through the use of manufacturer instantly redeemable coupons.  Based on the analysis of findings from these 73 studies, our fear is that as alcohol price goes down, alcohol consumption will increase as will alcohol-related harm.  To best protect the public, we suggest not allowing manufacturers to issue instantly redeemable coupons.  However, if the ABC wishes to implement this mechanism, we suggest only allowing a 10% reduction in price rather than 50% to mitigate the potential alcohol-related harm.  To minimize the impact of these instantly redeemable coupons we also suggest limiting the method of coupon delivery to print materials (print media or direct mail) and not on the Internet or electronic mail.

Guide to Community Preventive Services. Preventing excessive alcohol consumption: increasing alcohol taxes. www.thecommunityguide.org/alcohol/increasingtaxes.html. Accessed 8/13/2012.

Do not allow instantly redeemable manufacturer coupons.

Per *many academic and U.S. Gov. studies plus practical and business sense:

1) Alcohol consumption is responsive to price. Studies showed higher alcohol prices were consistent with fewer motor vehicle crashes and fatalities, less alcohol-impaired driving, less violence and fewer deaths.

2)Youth are particularly sensitive to price.  And in Va., far too many youth now are harmed/ killed from DUIs/ incidents affected by alcohol impairment.

*Do not lower the price of alcohol by allowing manufacturer coupons.

* Too few Benefits/ Pros presented/ in the record, versus the hugh Costs/ Cons with this reg. proposal.

These new rules would increase the maximum dollar value amount from $10 to $20 for give-away novelty and specialty items bearing alcoholic beverage advertising and allow contributions of alcoholic beverages to charitable groups (to be served) for service at events.

Again, per essential "due diligence", with Pros & Cons, for any such alcohol control or controlled substance regulation, the record shows very inadequate "Pros" here and too much focus on short-term profits for any sellers/ wholesalers involved.  Discard these proposals.

Do not allow instantly redeemable manufacturer coupons. Alcohol consumption is responsive to price.  Studies showed higher alcohol prices were consistent with fewer motor vehicle crashes and fatalities, less alcohol-impaired driving,  less violence and fewer deaths.  Youth are particularly sensitive to price. Do not lower the price of alcohol by allowing manufacturer coupons.