SPIR4230 - Technical guidance: Can a trader manufacture spirits in a still which has a capacity of less than 18 hectolitres?

ALDA section 12(5) (SPIR3090) gives us the power to refuse to issue a distiller's licence to a trader whose largest still has a capacity of less than 18 hectolitres. 

However, we will consider distiller's licence applications, providing the still will be used for commercial production of spirits. We require a business plan to support the application for commercial production.