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Members have asked us to better explain what the COCREA project consists of and what actions have been taken by APLA in relation to it. This document aims to take stock of the issues in order to better understand the evolution of this project. In context Located on the shores of Lac de l’Achigan, the Bruchési Health Camps, a non-profit organization, was created in 1936 as a hospital to fight tuberculosis. The government, social organizations and many individuals donated funds to purchase land and build dormitories and buildings. In the mid-1960s, its vocation evolved into that of a children’s holiday camp. Towards the end of the 1990s, the Camp was closed, then reopened, unsuccessfully put up for sale in 2008 and operated by Plein Air Bruchési to this day. A cadastral subdivision took place in 2014 to divide the land into three lots. Many citizen attempts have been made with the Quebec government and the administrators of Camps de Santé Bruchési to ensure the sustainability of the camp as a community organization managed according to rules of sound governance, formed by members of our community and led by a representative board of directors. The government has repeatedly stated that it does not interfere in the activities of a private company, even if it is a non-profit organization. In 2018, one lot and the majority of the Camp buildings were sold to Groupe R3 and the other two lots were sold to COCREA Immobilier in 2022. These are two companies headed by Mr. Eric Desroches. The COCREA project is planned for the lots acquired in 2022. Zoning and town planning In 2019, the Municipality carried out an overhaul of the urban planning regulations applicable to its territory to comply with the development plan developed by the MRC Rivière du Nord. Public consultations were held to obtain citizen comments.

When it comes to zoning, the first thing to understand is that a lot is located in a zone. We then specify the uses permitted according to the nature of the zone where it is located.  Uses are grouped by class: residential, recreational, commercial, industrial, agricultural, etc.

The 3 lots forming the land previously owned by Les Camps de santé Bruchési are located in a recreational zone. This only allows the use of holiday camps.

Holiday camps, a historical heritage in our territory, are the subject of a specific orientation in terms of town planning: “ensuring the sustainability of existing camps and restricting their transformation”. Following the adoption of the guidelines, a committee took charge of this file and the regulatory modifications were adopted on November 12, 2019. For the purposes of municipal zoning, a clear distinction is made between a holiday camp and a holiday center in terms of definitions and, class:

1)“A holiday camp is a place generally set up in the great outdoors and which offers, in a community format, a stay and organized activities for children, adults or families during the holidays”.  This is an activity classified as recreational.

2)''A holiday center is an establishment which offers, for a fixed price, accommodation, catering or self-cooking services and recreational activities or entertainment services, as well as facilities and equipment leisure.'' This is an activity classified as commercial. Our actions linked to the COCREA projectFor the purposes of municipal zoning, a clear distinction is made between a holiday camp and a holiday center in terms of definitions and, class:

Our actions concerns the COCREA project. The developer announced in 2021 a project called COCREA on part of the Camp Bruchési site. The APLA became aware of this project and informed the Municipality that it considered that the project was in fact a vacation center and therefore did not respect the zoning permitted on the site.

Last June, the municipality granted a certificate of authorization for the COCREA project to carry out holiday camp activities there. The next step is to apply for permits and the project will be spread over several years. We were surprised by the issuance of this authorization and we asked the mayor questions on numerous occasions.  Citizens also asked numerous questions during the municipal council meetings that followed. During these discussions, the Municipality reiterated that this project complies with zoning regulations.

The APLA asked the Municipality on multiple occasions to present a legal opinion regarding the conformity of the COCREA project with the zoning regulations in force.  As we did not receive a response to our request, we then mandated a law firm to obtain information from the Municipality regarding zoning, find out the authorizations and permits granted, validate compliance or not with the zoning and we advise in this matter.

In August, the project promoter held a public information session on the project.  COCREA Immobilier plans to build several new residential developments, catering services, outdoor amphitheater, spa, nautical activities center in order to hold recreational activities aimed at tourist and business customers purchasing packages.  This is a separate project from the summer camp activities currently held on one of the camp lots.  Representatives of APLA attended this presentation and we still believe that this project is in fact a vacation center. Citizens published an opinion letter in the September 2022 edition of Journal Le Sentier. They presented their social, environmental and urban planning concerns which were the subject of discussions with the developer during the information session. In the article, they expressed a need for information relating to the impact studies, to know the content of the Municipality's legal opinion and they deplored a lack of consultation before the issuance of the certificate of authorisation.   The mayor then published a letter in the Journal le Sentier in response to it. The mayor indicates that the two definitions (holiday camp and holiday centers) existed in the April 2019 regulation, that there was a shift in positioning in the use classes and that ''despite this regulatory modification, the two terms are so similar that we cannot exclude the uses of a holiday center from it'' and therefore the project complies with the regulations according to him. Our lawyers carried out an exhaustive analysis of the regulations and the project as presented by the developer. They determined that the COCREA project is in fact a vacation center, due to the nature of its activities and infrastructure, the offer based on packages, the targeted clientele, the lucrative nature and the liability to taxes applicable to a shop. This project constitutes a commercial activity which is not authorized according to the zoning regulations applicable to the lots on which the project is planned. This confirms the representations made by APLA to the Municipality. A formal notice was sent to the municipality informing it of this. He was asked to ensure the conformity of activities on the lots.  This means that the certificate granted is for summer camp activities and that only these activities must take place there. The problem is that the COCREA project activities are not compliant.

We have asked to suspend the study of any project or the issuance of any new permits related to the COCREA project, as it is envisaged, or any other project and to inform us of any developments. In response to the formal notice, the municipality's attorney emphasizes that the municipality has notified its insurer considering the alleged errors in contravention of the regulations and, consequently, will not discuss the zoning arguments raised in the formal notice. The municipality denies any allegation of fault and has no intention of revoking the certificate of change of use granted. It is mentioned that the municipality does not intend to modify its zoning by-law because the project presented complies with the uses authorized in this zone.

At this stage, you will understand that the APLA, concerned with its primary mission, is in total disagreement with the position of the Municipality. Despite our differences of opinion, please know that we always favor dialogue with the Municipality in order to resolve this dispute as quickly as possible. Many of you expressed your support for the steps taken last October by sending a support email and we thank you for your support. We will keep you informed of the evolution of this important issue for our community.

Thank you for your attention, Yvan Gingras, President of the APLA

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