Comment on FR Doc # 2026-08925

I am writing in support of the Bureau of Alcohol, Tobacco, Firearms, and Explosives’ proposed rule clarifying the definition of “business premises” for Federal firearms licensees. I support the proposed clarification because it is a practical and reasonable update. Many licensees operate using multiple nearby, adjoining, or functionally connected spaces, and requiring separate licenses or variances for each such location can create unnecessary administrative burden without materially improving public safety, recordkeeping, tracing, or ATF’s ability to conduct lawful inspections. Treating adjoining or adjacent business properties as a single licensed premises in appropriate cases is a common-sense reform that better reflects how many small businesses actually operate. I especially appreciate that the proposal appears to reduce unnecessary paperwork and compliance costs while preserving ATF’s existing ability to inspect licensed premises, firearms inventory, required records, and places of storage consistent with applicable law. At the same time, I respectfully request that ATF include clear language in the final rule, preamble, or guidance confirming that this clarification does not expand inspection authority into private residential areas of a home-based FFL that are not used for licensed activity, firearms or ammunition storage, required records, or public access. This clarification would be particularly important for small home-based FFLs that operate from a separate structure on residential property, such as a detached garage, workshop, outbuilding, or similar defined business area. In those situations, the licensed activity may occur entirely in the separate structure, while the residence itself remains a private dwelling and is not used for the firearms business. For example, if an FFL operates from a detached garage on residential property, and the private home is not used for licensed firearms activity, inventory storage, required records, ammunition storage, or customer access, the final rule should make clear that the private living areas of the home are not converted into inspectable business premises merely because they are located on the same residential parcel, or because the rule recognizes adjoining or adjacent property as part of the licensed premises in other contexts. I believe this clarification would support the purpose of the proposed rule while avoiding confusion for both licensees and inspectors. It would also help ensure that small home-based FFLs can comply with the law while maintaining clear boundaries between their licensed business areas and private residential spaces. To that end, I respectfully suggest that ATF consider adding language substantially similar to the following: “For a licensee operating from a residence or from a separate structure located on residential property, this definition does not, by itself, make private residential living areas part of the licensed business premises unless those areas are used for licensed activity, storage of firearms or ammunition, required records, or public access related to the licensed business.” This clarification would not limit ATF’s existing lawful inspection authority over licensed premises, business records, inventory, or places of storage. Rather, it would confirm that the proposed rule is intended to address the licensing treatment of adjoining or adjacent business premises, not to expand inspection authority into private residential areas unrelated to the licensed firearms business. For these reasons, I support the proposed rule and urge ATF to finalize it with an express clarification protecting the distinction between licensed business areas and private residential areas for home-based FFLs. Respectfully submitted.