CONTENTIEUX DES AUTORISATIONS D’URBANISME
par Jacques-Alexandre BOUBOUTOU
Avocat à la Cour
Le recours en annulation d’une autorisation d’urbanisme est introduit devant le Tribunal administratif du lieu de situation de l’immeuble. Le ministère d’avocat n’est pas obligatoire en première instance, toutefois il est conseillé d’y recourir pour plus de sécurité tant la procédure administrative, encadrée dans des délais rigoureux, est complexe et précise, particulièrement en droit de l’urbanisme.
L’intérêt à agir des requérants
Les personnes physiques ou morales autres que des associations et des collectivités sollicitant devant le juge administratif l’annulation d’une autorisation d’urbanisme, doivent justifier à la fois d’un intérêt direct mais également personnel.
Le juge s’emploie à prendre en compte tant la situation géographique du requérant que l’importance du projet de construction litigieux.
Aux termes de l’article L. 600-1-2 du code de l’urbanisme, et en sus de justifier d’un intérêt direct et personnel, un requérant ne sera fondé à agir à l’encontre d’une autorisation d’urbanisme que si les travaux projetés « sont de nature à affecter directement les conditions d’occupation, d’utilisation ou de jouissance du bien » qu’il détient ou occupe régulièrement ou pour lequel il bénéficie d’un avant-contrat.
Les associations peuvent également solliciter l’annulation d’une autorisation d’urbanisme sous les conditions suivantes :
- l’objet social de l’association doit correspondre à la défense du droit en cause.
- le champ d’intervention géographique de l’association notamment au regard de la proximité du projet.
- les statuts de l’association doivent avoir été déposés en préfecture avant l’affichage en mairie de la demande d’autorisation d’urbanisme par le pétitionnaire conformément à l’article L. 600-1-1 du Code de l’urbanisme.
Lorsque l’association est agréée au titre de l’article L. 141-1 et 2 Code de l’environnement, l’intérêt à agir de cette dernière est présumé.
La suppression de l’appel dans certains cas
Le décret n° 2013-879 du 1er octobre 2013 a pour objet notamment de supprimer la voie de l’appel pour un certain nombre de recours. Il s’applique provisoirement du 1er décembre 2013 au 1er décembre 2018 concernant :
- les permis de construire ou de démolir un bâtiment à usage principal d’habitation ;
- les permis d’aménager un lotissement lorsque le bâtiment ou le lotissement est implanté en tout ou partie sur le territoire d’une des communes mentionnées à l’article 232 du Code général des impôts et son décret d’application.
Il s’agit des communes appartenant à une zone d’urbanisation continue de plus de 50 000 habitants où il existe un déséquilibre marqué entre l’offre et la demande de logements, entraînant en conséquence, des difficultés sérieuses d’accès au logement sur l’ensemble du parc résidentiel existant.
L’obligation d’enregistrer les transactions
Aux termes du nouvel article L. 600-8 du Code de l’urbanisme, il est possible de prévoir une transaction par laquelle une personne ayant demandé au juge administratif l’annulation d’un permis de construire, de démolir ou d’aménager s’engage à se désister de ce recours en contrepartie du versement d’une somme d’argent ou de l’octroi d’un avantage en nature doit être enregistrée conformément à l’article 635 du Code général des impôts.
L’ordonnance prévoit également que si la transaction n’est pas enregistrée, la contrepartie qu’elle prévoit est réputée sans cause et les sommes deviennent alors sujettes à répétition.
Les acquéreurs successifs de biens ayant fait l’objet du permis contesté peuvent également exercer l’action en répétition à raison du préjudice qu’ils ont subi ce qui permettra à l’administration fiscale d’identifier les « serial monnayeurs » de désistements.
Les délais de recours
Le délai pour effectuer un recours en annulation d’une autorisation d’urbanisme est de deux mois à compter de l’affichage du panneau sur le terrain pour les tiers et de la notification pour le bénéficiaire.
Cet affichage doit être effectué en continu pendant les deux mois sur un panneau rectangulaire dont les dimensions sont supérieures à 80 cm.
Il doit être lisible depuis toutes les voies publiques bordant la construction.
Le panneau d’affichage doit également comporter les mentions suivantes :
- les nom et prénom du bénéficiaire (personne physique) ;
- la raison sociale ou la dénomination du bénéficiaire (personne morale) ;
- la date et le numéro du permis de construire ou de la déclaration de travaux ;
- la nature des travaux ou du projet ;
- s’il y a lieu, la superficie du terrain, la superficie du plancher autorisée ainsi que la hauteur de la construction exprimée en mètres par rapport au sol naturel ;
- l’adresse de la mairie où le dossier peut être consulté,
- l’indication des voies et délais de recours.
Il est vivement conseillé d’effectuer trois constats d’huissiers (au début, au milieu et à la fin du délai de deux mois) à titre de preuve de l’affichage régulier du permis.
La notification obligatoire
Conformément à l’article R. 600-1 du Code de l’urbanisme, le requérant doit à peine d’irrecevabilité de son recours notifier par LRAR son recours au pétitionnaire, titulaire de l’autorisation d’urbanisme et au service instructeur ayant délivré une telle autorisation dans un délai de 15 jours.
La notification doit porter sur le texte intégral du recours en annulation. Le simple courrier consistant à informer le service instructeur et le pétitionnaire de la saisine de la juridiction administrative ne saurait suffire, et emportera l’irrecevabilité de la requête.
Une copie du certificat de dépôt de la lettre recommandée doit être adressée au greffe de la juridiction pour preuve. C’est la date portée sur le certificat de dépôt en Poste qui fait foi.
Cette obligation vaut tant pour le permis de construire, que le permis d’aménager, de démolir, la déclaration préalable ou le certificat d’urbanisme.
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