Letter from the table: A permit clock cannot decide what is safe

To the Red Tape Council,

RC/RT/2026/T.35 · 1 May 2026

I oppose RT-001 as written. I want shorter, clearer permit processes. I do not want a rule that treats a municipality’s silence as permission to operate when the question still waiting for an answer is whether a proposed use is allowed at that address.

In January 2025, I was arranging to move my work into a small rented premises in Mérida. Before opening, I needed to understand whether the intended use was compatible with the location and what the Ayuntamiento de Mérida required for a municipal Licencia de Funcionamiento. Those are connected questions, but they are not interchangeable: land use depends on the property and its permitted use, while the operating licence concerns the establishment. I needed to settle both before I could responsibly begin.

I signed a lease on 10 January, with the rental period beginning on 1 February. The rent was MXN 8,500 a month. I paid a MXN 17,000 deposit and the first month’s rent. I had chosen the space because it was affordable and close enough for me to manage. I had not budgeted for a long period in which I would be paying for a place I could not yet use.

On 13 January I went to seek guidance from the municipality. I took the lease, identification, tax information and details of the address. The first question was not simply which form to fill in. I needed confirmation about the proposed use of the premises and the property information relevant to that review. I then had to obtain additional documents and arrange a technical drawing. I returned with what I had been asked to

provide; the material had to be reviewed before I could proceed with the operating licence.

I am not saying that every delay was the fault of one office. Some information had to come from the property owner, and I could have checked the land-use question before signing. I also learned that a requirement that sounds simple in a general description can depend on the activity and the specific address. But as a small operator, I had no case manager who could tell me, in one place, whether the file was complete, which review remained open, and what would happen next. I made trips, followed up, and paid MXN 4,200 for help preparing the drawing and about MXN 620 for transport and document costs.

The process was resolved in March. I was able to proceed with the municipal requirements and began using the premises on 17 March. By then, about six weeks of rent had passed while I was waiting and dealing with the requirements. That is roughly MXN 12,750 in rent for the idle period. Add the drawing and document-related costs, and the delay cost me at least MXN 17,570. That does not count the time I spent away from my work, the deposit tied up in the lease, or the income I could not earn there.

I understand the attraction of a “silence is consent” deadline. A business owner should not be left indefinitely without an answer. But automatic approval would not have made my address suitable or completed the land-use review. It could instead have left me relying on a permission that a later inspection or decision might question. That risk would fall on me, not on the office that missed its deadline. It could also affect neighbours and other people who rely on the rules governing what can operate in a particular place.

For that reason, I oppose the proposed standard as a package. I support testing the effect of new rules on small businesses, a simpler point of entry for applications, and published service times. I would add a clear receipt confirming what has been submitted, a visible status tracker, a named office responsible for the next step, and a written notice when an

application is incomplete. If a target time is missed, the applicant should have a prompt escalation route and an explanation—not an automatic permission that may not settle the underlying question.

The Council should also distinguish between a delay caused by an office and a delay caused by missing information, a property issue, or a review that needs input from another department. Publish target times for each stage, say when the clock starts and pauses, and report how often targets are met. For low-risk applications that are complete and do not raise land-use or safety questions, the Council could consider a carefully defined interim route. But silence should not substitute for a decision where the decision matters.