Okay, here's what I sent to PLCB legal department, who then said they would get back to me in 6 weeks.... (mods, feel free to delete if I put info on the following that would get the site in trouble)....
My name is Bill ******* and I am writing on behalf of Bushy Run Winery (LID# *****). We are seeking to obtain a limited winery license from the PLCB. We recently received a correspondence from the PLCB informing us of issues concerning my wife”s (Karen *******) involvement in the winery as she is employed during the workday by All City Hospitality in the position of Human Resource/Accounting Manager. All City Hospitality has a pre-existing PLCB license for their bar at their hotel (the Ramada Inn and Conference Center located in Greensburg, PA). Please note that other than hiring and firing employees and writing checks for the hotel’s bills, she has no other dealings with the bar/liquor license. Her impact on the bar's operation is negligible at best.
At issue is the PLCB code 443 (d) of the Pennsylvania Code which states that no employee of a licensed hotel or restaurant shall in any wise be interested either directly or indirectly in the ownership or leasehold of any property or the equipment of any property or any mortgage lien against the same used by a manufacturer to manufacture liquor or malt or brewed beverage, nor shall any hotel, restaurant or club licensee, or any officer, director, stockholder or agent or employee of such licensee, either directly or indirectly lends any monies, credit or anything of value or the equivalent thereof to any manufacturer for equipping, fitting out, and maintaining and conducting, either in whole or in part, an establishment used for the manufacture of liquor or malt or brewed beverage.
Please note that the specific fermentation of grapes (wine) is excluded from this detailed code.
We feel that this section of the code is over-reaching and limiting.
We do not contest that Karen ******** works for All City Hospitality (Hotel Liquor license H-****/LID ***** from the hours of 8am to 5 pm. When working at the hotel, she devotes 100% of her effort to the hotel. She is not a decision maker on any part of the part of the liquor licensed area, with the exception of offering or terminating employment and benefits for the hotel’s employees and processing checks for the hotel’s bills. However, at the end of the work day, the employer/employee relationship between her and the hotel ends. She receives no compensation for her time not at the hotel, nor is she bound by any restrictions from the hotel during her time not at the hotel.
After her arrival at our home where the winery is seeking to be established, she can then be in the employ as Manager of Bushy Run Winery, where she can devote 100% of her time to the winery during the hours established with the PLCB application. During this time, an employer/employee relationship will exist between her (as manager of the winery) and the winery. She will not be working on any of All City’s causes or requirements. In this way, there will be a distinct separation of the employments.
In addition, we also seek the question the enforceability of this clause on hotel employees, officers, directors, stockholders, or agents. We believe that the PLCB will agree that a benefit for hotel and restaurant employees at various locations will include the provision of a 401K/IRA. As these retirement vehicles include mutual funds, the mutual funds may include investing in businesses which include other PLCB licensees (such as hotels and restaurant chains, InBev, Budweiser, Coors, etc). This would put a large majority of existing hotel and restaurant employees in violation of this PLCB code. We feel certain that the PLCB would not look to un-employ vast numbers of hard working PA business employees which are saving for retirement or to have their retirement funds restricted just to comply with an overly restrictive state code.
It is with these two reasonable issues that we seek to appeal the issues raised by the PLCB with Bushy Run Winery’s Limited Winery License.
Started tidying a bit for tomorrow: out buyer asked to come by to measure some windows and ask some questions about the yard, routine maintenance we've done and what all the wires coming out of the family room wall go to (I have four sets of speakers, along with ethernet, HDMI, etc all coming into a hub there) 
