Open letter from Nature Protection Committees of Brussels

Document Adobe Acrobat 74.0 KB

Version française



Brussels, August 5th 2013


Open letter to the attention of :


Mr Rudi Vervoort, Minister-President of the Brussels-Capital Region,

Mrs Évelyne Huytebroeck, Minister of Environment of the Brussels-Capital Region,

Mr Willy Decourty, Mayor of Ixelles (1050 Brussels),

Mrs Nathalie Gilson, Deputy burgmaster for Town Planning at Ixelles,

Mr Jean-Pierre Hannequart, General Director at IBGE (Brussels Institute for Environment, now named Brussels-Environment),


[ Copy to the to the Government of the Brussels-Capital Region and to the members of the Brussels Parliament, as well as to the Civil Society and the Medias ]


Subject: “La Plaine” (ULB) – Project Universalis Park : say STOP !


Mr. the Minister-President,

Mrs. the Minister,

Mr. the Mayor,

Mrs. the Deputy burgmaster,

Mr. the General Director,


Ladies and Gentlemen,



1/   The origin of the problem

2/   A growing protest

3/   Unsatisfactory answers to our legitimate questions

4/   The wish of a great part of the students and citizens


1/ The origin of the problem


The green space of La Plaine in ULB's campus (close to VUB's) brings a twofold benefit (ULB=Free University of Brussels, VUB is the equivalent in Dutch):


- on one hand it is composed of well-maintained fields that students and neighbours use alike a common good,

- on the other hand it is formed by wilder green spaces, giving shelter to a biodiversity and a wildlife that are only too scarcely found within the town area.


The importance of such green areas couldn't possibly be emphasized enough; they are part of the Green Meshing and also an inclusion of the nearby forest into the town area.


The project “Universalis Park”, put forward by Immobel, gives rise to the students’ and citizens’ movement protest and this for two main reasons:


- it is planned to build upon green spaces when we could be building elsewhere : indeed, even in Brussels, one can still find abandoned (industrial, urban) wastelands and we do not refer to the millions of square meters of empty offices and apartments in the city (2)


- the planned buildings will enclose high-level apartments on a university campus precisely where there is a lack of affordable housing solutions for students : surely, the introduced construction permit includes some good elements (a nursery, two shops, ...) but they are nonetheless essentially pertaining to high-standing housing ...


2/ A growing protest


The indignation became most visible during the “consultation commission” of June 19th 2013 at the town hall of Ixelles :


- more than a hundred citizens attending (far more than the municipal room capacity)

- hundreds of written protest letters sent to the municipality (Ixelles) before that date

- an online petition exceeding 4.400 signatories

- representatives of several organizations and committees attending the event

- massive media covering


What was the result of that “consultation commission” ? Out of 6 votes, 2 votes in favour (among which Ixelles), 1 vote against (Auderghem) and 3 blank votes ... among which the IBGE (Brussels Institute for Environment, now named Brussels-Environment)!


The IBGE is precisely supposed to take care about preserving the environment and the green spaces. Accordingly, last year, they had voted against the project. What concrete elements may have possibly lead the IBGE to no longer vote against ? Indeed, even though the previous project has been modified, it remains to our belief largely unacceptable and the two above mentioned main reasons still constitute an unacceptable situation.


3/ Unsatisfactory answers to our legitimate questions


Because our questions were eluded or answered wrongly during the “consultation commission” of June 19th, we formulate them again hereafter :


3.1. If “Universalis Park” is of no harm for the site's biodiversity why don’t they plan an independent impact study, beforehand (the law allows the Authorities to enforce one) ?


3.2. Is it correct that, if a construction permit would be introduced for what seems to be the whole of the project (see the impact report of Art&Build, the architects themselves), an independent impact study would then be mandatory ?


Isn’it uttermost obvious that there is here a “slicing” aiming at eluding the need of such an independent impact study ?


3.3. If there is already an ongoing PPAS (particular plan to allocate the ground) or this site, why does it not encompass the introduced permit, just as it encompasses the rest of Immobel's zone ? What is the urge of such a project in terms of town planning for the Municipality ?


3.4. Given the demography problems that Ixelles (Brussels) faces, in particular at the student level, would it not be wiser to plan student housings, even more when it is on an universitary campus


3.5. How long has it been since the IBGE did carry out a serious study of La Plaine's biodiversity ? Given that the site has developed years along its wildlife in the past decades, now giving shelter even to protected species, how could one justify that more attention should not been paid to the site during the updates of the PRAS (Regional Plan for Ground allocation)? Moreover, are the areas labelled “green zones” in the PRAS the only ones to deserve being preserved as such? (3)


3.6. In light of the citizens’ arising protest, how could we consider this type of actions: a denial of democracy on this matter. Very much akin to the events that took place regarding the Avenue du Port ? As a reminder, the latter permits where finally denied, following the citizens’ claims.


4/ The wish of a great part of the students and citizens


The concerned piece of land is today owned by Immobel, who bought it from ULB in 2007, at that time facing a financial crisis. But that does not grant Immobel the right to build anything they want on a high-biological value area, and even less so if it is a project of virtually no interest for the students and neighbours, and spoiling Ixelles' largest green space.


If these (urbanism, road and environment) permits would be delivered, the committee “Saving La Plaine / Against Universalis Park”, backed up by the neighbouring committees of Brussels as well as by several organizations, will be ready and daring to introduce a procedure to the State’s Council.


The protest put forward by the committee “Saving La Plaine / Against Universalis Park” is backed up by:


- Bureau des Étudiants Administrateurs de l'ULB (BEA),

- Bruxelles Nature ASBL (“groupement d'associations de défense de la Nature à Bruxelles”),

- Centre d'Écologie Urbaine ASBL,

- Fédération des Étudiants Francophones (FEF),

- Jeunes Natuurlijk.


We shall fight for our democratic will of denying this project and the corresponding permits.


We shall fight for Brussels' green meshing, its green spaces, and for a consistent development of our university sites citizens and tourism.


This, having in mind the preservation and even potential development of our green, ecological, social, cultural and scientific patrimony.


Hoping that you will consider our point of view, we are, Mr. the Minister-President, Mrs. the Minister, Mr. the Mayor, Mrs. the Deputy burgomaster, Mr. the General Director, Ladies and Gentlemen, yours faithfully.


– For the committee “Saving La Plaine / Against Universalis Park”, Gustavo Lucena Gómez

– For the committee “Défense de l'Altitude Cent”, André Robe

– For the committee “Longchamp-Messidor-(Churchill)”, Anita Nys

– For the committee “Tervueren”, Philippe Elsen




Contact person: Gustavo Lucena Gómez,, +32 494 93 72 57



(1)   IBGE (Bruxelles-Environnement), “Un plan pour le développement de la nature et de la biodiversité à Bruxelles”, 03/09/12. See also

(2)   For example the southmost part of the nearby “triangle Delta”, that the upcoming Chirec hospital shall not occupy. See also RTBF Info, “Les bureaux vides représentent 1 200 000 m² de surface inoccupée à Bruxelles” (Empty offices represent 1 200 000 m² of unoccupied area in Brussels), 02/03/12, Jean-Claude Hennuy.

(3) The area is labelled “zone d'intérêt collectif” or “de service public” in the PRAS (Regional Plan for Ground allocation) as well as partially “zone à haute valeur biologique” (area of high biological value) and even “zone noyau” (core area) in the PRD (Plan Régional de Développement) - IBGE, “Registre des zones protégées” (Record of protected areas), novembre 2010.

(4) See



Information : website


Protesting: Avaaz petition "Empêcher la construction de logements privés sur le plus grand espace vert d'Ixelles" (Preventing the erection of private housings on Ixelles’ largest green space)


Joining us: Facebook group “Contre UNIVERSALIS PARK et la destruction du campus de la Plaine” (Against UNIVERSALIS PARK and spoiling of campus La Plaine)