Letter from the table: The cost of waiting for a permit

To the Red Tape Council

I oppose RT-001 as drafted. I want published service times, a single place to follow an application, and a meaningful test of how new rules affect small businesses. But I do not support treating a permit as approved merely because a deadline passed without a decision. My own experience is why I draw that line.

On 2 April 2026, I submitted an application to the City of Québec for a permit connected with a modest interior fit-up in the premises where I work. I had checked the City’s permit information and the zoning rules that applied to the address. I understood that the proposed work needed municipal review, so I applied before starting it. I am not setting out the address or the nature of my business; neither is needed to explain what the wait did to my plans.

I prepared the forms, paid the application fee, and included the plans I had been asked to provide. On 16 April, I checked the online file and saw that it had not moved to a decision. I contacted the City’s permit service to ask whether anything was missing. I did not receive a decision that day. On 6 May, I uploaded an additional drawing and a clearer description of the work, because I wanted the reviewer to have enough information to assess it. The file still showed that it was being reviewed.

I know that a permit review is not just a queue number. The City has to check whether proposed work complies with applicable municipal rules and building requirements. A delay can reflect a real question about a plan, not neglect. From outside the process, however, I could not tell whether my application was waiting for a reviewer, waiting for a technical check, or waiting because something else was required from me. I kept checking and

asking rather than assuming that the absence of a message meant the application was complete.

That uncertainty changed what I did. I did not start the work. I kept using the existing arrangement in the premises, even though it was less efficient for the way I needed to operate. I postponed a purchase connected with the fit-up and rescheduled a tradesperson rather than risk paying for work that might have to be changed. The rescheduling cost me CAD $620. I also paid CAD $1,140 for short-term storage for equipment that I had expected to put into use after the work. Those sums were not dramatic enough to appear in a public debate about regulation. They were large enough to affect my cash flow.

By 18 June, I had adjusted the plan again. I separated the work into steps I could take without crossing the line into work that required the permit, and I kept the rest on hold. I made another inquiry through the City’s existing contact route and retained copies of the application, the extra drawing, and my follow-up. I was trying to be a careful applicant, not to find a shortcut around the rules. The practical burden was that I had to spend time proving to myself that I had done what I could, while still not knowing when I could make the next commitment.

This is why parts of RT-001 matter to me. A one-stop digital process should let an applicant see what has been received, what remains outstanding, and who is responsible for the next step. Published service times should distinguish between a complete application and one awaiting information. If a file is paused, the applicant should be told why and what would restart the clock. Those changes would not guarantee that every permit is issued quickly. They would make it possible to plan and to correct an incomplete file without guessing.

But I oppose a general “silence is consent” deadline for permits. A missed deadline cannot tell an applicant whether the plans satisfy the rules, whether a safety issue needs attention, or whether the authority has not yet completed a necessary review. Deemed approval could leave a small operator carrying the risk of acting on an assumption the City later

disputes. It could also put staff under pressure to issue a rushed answer simply to avoid automatic approval. Neither outcome is fair to the applicant or to the public.

I would ask the Council to replace that part of the proposal with a clear escalation process. When a published service time expires, the applicant should receive an explanation, a named point of contact or team, and a firm date for the next update. Where the file is incomplete, the City should identify the missing items in one consolidated request wherever possible. If a review needs more time for a stated technical reason, that reason and the revised timetable should appear in the same tracking system. A delay should trigger accountability and information, not automatic permission.

Waiting for change has also changed how I run my business. I now build permit uncertainty into project schedules, keep more cash available for work that may be postponed, and avoid ordering equipment until I have a clear written decision. That is a sensible precaution for me, but it is not a good public process. Small businesses should not have to choose between taking a risk on an unclear file and paying to wait.