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