Give every permit a clock and a named owner

To the Red Tape Council,

A permit that arrives after the work has moved

In March, I arranged a short repair to the outside of the premises where I work. The contractor needed a small section of pavement for access equipment. Because the pavement is public space, I knew I could not treat this as an ordinary repair or assume that a building notice covered it. I checked the Comune di Bologna’s instructions and applied for temporary occupation of public land.

I filed the online request on 2 March for 13–15 April. I included the proposed dates, the area and dimensions, and a plan showing where the equipment would stand. I also asked the contractor to keep those dates open. I had submitted the application more than six weeks ahead; I thought that was a reasonable allowance for a short, planned job.

On 1 April, I was asked to provide a clearer drawing of the pavement area. I sent it on 3 April. I do not object to being asked for a missing or unclear document. The problem was that I could not tell, from the information available to me, whether my file was complete, which step it was waiting for, or when I should expect a decision. I had no reliable service time against which to plan.

On 9 April, with the requested dates approaching and no authorization in hand, I moved the contractor’s booking. The change cost me €420. I also paid €96 for storage and handling that would not have been needed if the equipment could have arrived as planned. The Comune issued the authorization on 23 April, for 27–29 April. The occupation charge quoted for those dates was €186.40, which I paid. The work was completed, but the permission came after the original booking had already become unusable.

I am not saying the Comune should have approved the request without checking it. Public pavement has to remain safe and usable, and an application can affect more than the person who submits it. I am saying that a business owner should be able to see what is being checked, what is still needed, and how long the process is expected to take. In my case, the uncertainty—not the fee—was the most expensive part.

Why I support the proposed standard

I support the Red Tape Council’s proposed Small Business Impact Standard: test new rules against the practical burden on small firms, make the process easier to navigate, publish service times, and set a clear consequence for an unanswered application where the law allows it.

My practical proposal is to make the standard work through one application record and one visible clock. A person applying for a permit should receive a reference number and a checklist that identifies the documents needed for that application. The record should show when it was received, whether it is complete, who is responsible for the next step, and the target date for a decision. If the authority needs more information, it should say what is missing and whether the service clock pauses while the applicant provides it.

For an application that involves several offices, the applicant should not have to guess which office is holding the file or repeat the same information at each counter. The relevant offices can continue to carry out their own checks, but one named contact or team should be accountable for keeping the applicant informed. A short status message at each hand-off would make a real difference: received, completeness check, technical review, decision. These are ordinary pieces of administration, but they let a small firm plan people, contractors and cash.

Published service times should also distinguish between different kinds of request. A straightforward, complete application for a short occupation is not the same as one that changes traffic arrangements or raises a safety or heritage issue. The authority can publish separate targets and explain the

exclusions. That is more useful than one impressive headline number that does not tell an applicant what to expect in their case.

I support a “silence is consent” deadline only where it is lawful and appropriate. It should not override a safety check or another legal restriction. Where automatic consent cannot apply, the deadline should still require a recorded decision, an explanation for delay, and a clear escalation route. If the application is incomplete, the applicant should be told promptly—not left to discover the problem when a booked date is nearly here.

The Days to Open survey is a good way to compare what applicants actually experience across cities. I hope it records not only the number of days, but also whether the published time was easy to find, whether the applicant received a completeness check, how many times they had to resubmit information, and whether a late decision caused a measurable cost. Those details can show which changes improve the process rather than merely move the paperwork.