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Rye Frenzy

DSP location question

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Hello everyone.  I’ve been lurking and browsing the site for a while as I was figuring out how I wanted to start my operations and now that I’ve got most of my basics and am ready to apply for my DSP, I’ve finally made an account to post some remaining questions.  First up is a question about DSP approval for a location I’ve found.

Quick background: my current business plan is to contract my first batches of whiskey while I establish my brand and look for additional funding to set up my full distillery.  So for right now I only need to establish a warehouse DSP, with the potential for doing warehouse + processing - I won’t be bottling for at least 2 years, so I’m focusing on locations that are quick closure for warehousing purposes instead of more robust with utilities to do processing/bottling.  While not ideal, I’m willing to re-address this in 18 months after our economy bounces back (hopefully) and more locations are available.

My LLC is currently registered using a local co-working space as our physical and mailing address.

I have a promising location for warehouse operations picked out, but it’s sort of non-conventional.  The owner of a multi-acre plot of land is building a mini industrial park.  Right now it consists of a fenced/gated area that holds storage warehouses as a mix of self-storage + 20x40 standalone business warehouse facilities.  At the front is a 3-bay shop/office building, where each bay has a true public entrance outside of the fence.  There is currently a winery and 2 construction companies using those 3 spaces - the winery also has a standalone warehouse on-site.  The three units up front are the only ones that currently have official mailing addresses, but every interior unit has a dedicated “Unit ###” designation at the street address for easy identification.  While there is a gate, it is exclusively for vehicles and there is a pedestrian entrance that a TTB agent would be able to walk through 24/7 to reach our warehouse if necessary.

My question is, do you think TTB will approve this setup?  It seems logical to me, especially considering it’s just a warehouse DSP.  They have unfettered access to the location, the site owner actually reached out to me, so he’s on board, and AHJ is so far on-board with the plan so long as I’m not distilling on this site - which I likely wouldn’t even do processing in this space as it lacks a drain and other utilities.  Assuming this passes muster, would having my primary address at a co-working space and my warehouse down the road be considered non-contiguous locations?  I think it would, but maybe they only count actual DSP locations toward this?

For those who are considering asking, I have already considered trying to get set up in a more robust location and do a vodka, gin, and even sourcing aged whiskey.  But I’ve done extensive market research and sourced whiskey is a non-starter, and I’m not big into vodka or gin and don’t have the desire to maintain a product I couldn’t be enthusiastic about.

This is a lot to unpack, and the mini industrial park might need more clarification, but I’d rather be succinct and answer direct questions later than try to answer everything in a short novel.

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You plan to source bottled product, warehouse it and sell it where? If this is the case, you would need an Alcohol Wholesale/importer permit

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No.  I will be having whiskey produced under contract, then transferring the barrels in bond to my location where they will age, and then I will bottle and sell it.

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Sounds like a disaster in the making to me. That location has no provisions to do any type of processing so if used solely for barrel storage it would need to be zoned accordingly as a Hazardous location, and sprinklered appropriately. You'd then need a transporter permit and a processing permit when the barrels are aged. I'd post iup in the main forums to get some more input from those with much more knowledge and experience than me

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