Definition of Business Premises

Nathan Siegel of Sturm, Ruger & Company, Inc. supports the proposed rule to clarify that a licensed business premises may include adjoining or adjacent properties sharing a common parking lot, sidewalk, or road. The commenter argues that the rule provides practical operational flexibility and reduces administrative burdens for firearms manufacturers and dealers without compromising public safety.

The commenter, a Federal Firearms Licensee (FFL) and Special Occupational Taxpayer (SOT) owner of Silencer Central / BANISH Suppressors, supports the proposed amendments to clarify that "business premises" includes adjoining or adjacent properties. They argue that the change aligns with ordinary dictionary definitions, mirrors other federal regulatory practices, and removes unnecessary administrative burdens for businesses that have outgrown a single building.

Phillip Hagel, a private citizen and gun owner, supports the proposed rule to clarify the definition of "business premises." He argues that allowing FFLs to treat adjacent properties as a single location will reduce administrative burdens and costs for small businesses.

The commenter supports the proposed rule because it reduces administrative burdens and paperwork for small businesses by treating adjoining properties as a single licensed premises. However, they request specific language to ensure that the rule does not expand the ATF's inspection authority into the private residential areas of home-based firearms licensees.

An individual commenter opposes the ATF's proposed definition of "business premises," arguing that the term should be interpreted in its ordinary commercial sense without new regulatory intervention. They express concern that such a definition could be used to expand warrantless inspection authority and hold licensees liable for activities beyond their control, suggesting that the ATF should rely on case-by-case determinations instead.