Gus, the intent of this is to concentrate the FFL population. All it will take is the annual inspection visit, and oh,you have a LATHE or you're improving the product, so where's your expensive State Department license for "defense articles?" Including Nightforce scopes or other whatnot?
Oh, you don't have one? Here comes the State Department roving SWAT team....or the IRS inspectors.
Shrink the number of FFLs, then ATF gets to concentrate on those remaining.


Up hills slow,
Down hills fast
Tonnage first and
Safety last.