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Dear Alice:

What's up with the beer rules at Sea World? I'm an annual pass holder and often like to sample those 4 oz. cups of beer at the Hospitality Center. My question is, why are you not allowed to walk around the park with those, but you can buy a 16 oz. cup at the concession stands and go anywhere you want, with the exception of bringing it into the Hospitality Center. Sounds to me like someone who made the rules sniffed a little too much of the Clydesdale manure or ate a raw fish intended for Shamu.

-- Joe Wayton, La Mesa

We wanted to go to the source to get this answer, so the elves have set up a beer stand and dog wash in front of the house to raise the admission money. Business has been pretty good, but we're still a couple of thousand short, so in the meantime we checked in with the park's official spokesorca. We flipped him a couple of frozen herrings, and he disclosed that the beer situation at Sea World just reflects state law. It has to do with the kinds of alcohol licenses they have.

Do you know how much paperwork there is between your amber waves of grain and a cold one in a cup? The road from a blue agave in Mexico to a tequila shooter at your local Stagger Inn is paved with licenses, permits, agreements, decrees, scrolls, parchments, resolutions, pacts, treaties, authorizations, warranties, credentials, charters, permissions, and legal instruments. According the California Alcoholic Beverage Control, there are hundreds of different beer/wine and alcohol licenses available, depending on where you are in the booze food chain.

Licensewise, all of Sea World is divided into two parts. The Hospitality Center itself has a Type 23 license that permits a small beer or wine manufacturer to distribute samples on the premises. It's the kind of license a winery or a microbrewery would have for its tasting room. The license doesn't restrict the size of the sample or the number that can be given out; that's a corporate decision. But it does say that the sample has to be consumed within the licensed property. If you wander outside the boundaries of the Hospitality Center with your four-ouncer, you could single-handedly bring down the park's free-beer concession.

The rest of Sea World (except the parking lot and adjacent public areas) has a regular beer, wine, and distilled spirits license. This means you can carry your concession-stand beer anywhere within the park's walls, as if you were in your local tavern. You can wander over to the Hospitality Center and wave your 16-ouncer derisively at the schmoes stuck inside with their little samples. You just can't go inside because the Hospitality Center isn't licensed for beer sales, just give-aways.

But, hey-y-y-y-y-y, wait a minute. Isn't it illegal to give away alcohol in California? Bar owners can't even advertise two-for-one specials or buy-one-get-the-second-for-a-penny deals. They've already taken the ABC to court to try to get permission to hawk their product as if it were T-shirts or picture frames or pizzas. No deal, said the booze police. According to state cocktail regulations, any retailer appearing to make it easy for you to buy a drink or a bottle is committing the crime of "promoting the intemperate use of alcohol." As it turns out, that's why a Type 23 license is issued only to a manufacturer. If you make the stuff, you can give it away. If you sell it, you can't. Strangely enough, a retailer can legally advertise the usual $5.00 tub-o'-margaritas at the discount price of $2.50 per tub. For those of us living in the real world, this means you and your date are getting that forbidden two-for-one deal. Go figure. Uh-oh, gotta split. The elves are trying to hot wax a cat.

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