Virginia Petroleum Convenience and Grocery is pleased to strongly support the following reglatory change which was one of two suggested by this association

C. For a licensee that operates more than one retail establishment, each such establishment shall be considered a separate licensee for the purpose of this section.

Presently, there is uncertaintly in the convenience store industry that in the event that a violation of this section occurs, wheter that violation can be used in a punative way against other stores in the same chain owned by the same operator.

This recomended change assures that is not the case and is supported by the Virginia Convenience Store industry.   We appreciate ABC's consideration of our views in this matter

Michael J. O'Connor

President and CEO

Virginia Petroleum Convenience and Grocery Association

7275 Glen Forest Drive Suite 204

Richmond VA 23226

To allow instantly redeemable coupons - I oppose this change because it will encourage spontaneous purchases of greater quantities of alcohol and can lead to excessive drinking.

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 addition of language allowing a licensee owning more than one establishment to be considered a separate licensee for each establishment owned because owners of multiple locations can accumulate violations without getting the increased fines or suspensions that apply to repeat offenders as long as each offense occurs at a different location. If the owner has been found in violation, then there is no reason why that owner should be permitted to commit the same offense again.