Need more help on my TTB Comment Letter

As discussed in a couple of other threads, the Treasury Department is is soliciting comment on competition and barriers to entry in the beer, wine and spirits business in the US. Regulations.gov. I am working on a comment letter for the Wine Beer and Spirits Law Committee of the NYS Bar Association. So far, I have focused on industry concentration and antitrust issues. I knew it was bad, but the two largest distributors control over 50% of the nationwide market. Any other thoughts on other issues to be raised that would make it easier for the little guy to get into the business and compete? I am especially interested in comments from ITB people, but focus on federal barriers and issues. NOTE: TTB has no authority on state-mandated three tier distribution so that is off the table.

The Treasury announcement includes the following, which indicates the general ideas I am commenting on.

On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. Section 5(j) directed the Secretary of the Treasury, to submit a report within 120 days ‘‘assessing the current market structure and conditions of competition [for beer, wine, and spirits], including an assessment of any threats to competition and barriers to new entrants.’’ The report is to include discussion of unlawful trade practices; patterns of consolidation in production, distribution, or retail markets; and ‘‘any unnecessary trade practice regulations of matters such as bottle sizes, permitting, or labeling that may unnecessarily inhibit competition.’’