A deadline cannot make a permit safe

Letter from the table

To the Red Tape Council,

I oppose RT-001 as drafted. I want small-business impact tests, one clear place to submit documents, and service times that people can see. I do not support treating a permit as approved merely because an office has not answered by a deadline. That is not a shortcut I would trust, and it could turn an administrative delay into a dispute between neighbors, a business and the municipality.

I learned how quickly a permit question becomes a cashflow question in Mérida. On 3 February 2025, I committed to a small premises and paid MXN 15,000 for the deposit. The monthly rent was MXN 7,500. I had budgeted MXN 1,200 for the first utility bills while I prepared to open. I am not naming my business; the point is what a waiting period costs when there is no income coming in.

On 10 February, I began the municipal process for the premises. I understood that the file required the municipality to assess whether the intended use was compatible with the location before the municipal operating licence could be completed. The steps were connected, but they did not feel like one process from the applicant’s side. The land-use question depended partly on documents about the property, while I was the person trying to assemble and track the file.

I tried to make the application as complete as I could. I asked for the checklist, checked what I could obtain from the property owner, and returned to the Ayuntamiento de Mérida’s service desk when I could not tell whether the next step was waiting on me or waiting on the office. I kept copies of what I had submitted and the dates I had gone in. When a

document needed clarification, I followed up rather than assuming that the application had disappeared. I did not need a special favour. I needed to know what was missing, who had to act, and how long the next step was expected to take.

By 3 March, another month’s rent was due. By 17 March, I was still trying to establish the status of the file. The MXN 7,500 did not become less real because the application was under review. Nor did the utility costs stop. I was paying to keep a place available while unable to plan confidently around opening. The municipality’s decision mattered, but the cost of waiting landed on me.

This is why I see a direct link between Red Tape and Cashflow. A form that sits unresolved is also a bill that arrives before revenue. For a small operator, the difference between a clear request for one missing document and weeks of uncertainty can determine whether there is enough money left to continue. A digital one-stop process would help if it genuinely joined the steps, made responsibility visible and let an applicant see the status of the file. A published service time would help if applicants could tell when the clock starts, when it pauses, and what happens when the authority needs something else.

But silence is not a safe substitute for a decision. A missed deadline does not establish that a location is suitable, that the paperwork is complete, or that a condition affecting other people has been checked. If automatic consent is used, an applicant may believe they are protected while the municipality later says the file was incomplete or the wrong kind of approval was assumed. That uncertainty could bring more expense, not less. It could also put a small business in conflict with the people living or working next door.

I would rather see a rule requiring a written status by a published date: approved, refused with reasons, or still under review with a specific explanation and a new deadline. Where a public authority has missed its own service time, there should be a clear escalation route and a named next step. Where an applicant has not supplied a required document, the

clock should pause and the missing item should be identified plainly. Those protections would make delay visible without pretending that no answer means yes.

The Days to Open survey can help if it records the whole experience, not just the final number of days. It should distinguish time spent waiting for an authority from time spent obtaining documents from an owner or correcting an application. Otherwise, a single average can hide the very point where a fix is needed. I would also want the impact test to ask what a delay costs a small business before a new requirement is added.