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It should not be necessary to discuss at length the intention of a mysterious SPRL (Recumas not to be named) to establish a chemical plant in the heart of a small provincial village (Mazy, in the Namur region). The 

The common sense, which is also called « common sense » and which is politically founding, indicates to us immediately the total absurdity of such a project. Unfortunately, common sense has faded behind the rationality of techno-science and politics tends to rely on experts, destroying the conditions of possibility of its exercise; it is therefore not possible to escape contradictory arguments. 

To project the implantation of a plastic recycling plant in the heart of a village seems unheard of in Belgium, a country known for its surrealism and the attractiveness of its industrial zones. The list of concerns of the villagers is consequently very long; it probably overlaps with the one that the firemen will not fail to establish as soon as they are given the opportunity (why procrastinate?) 

Firstly, the village of Mazy is a residential village. It is difficult to see how the living environment of the villagers, and even less their quality of life, would be respected by such an implantation. In addition, the desired site is adjacent to a Natura 2000 area, crossed by an aqueduct, and located in the immediate vicinity of two elementary schools. Its location is difficult to access and its current roadway is not at all adapted to the passage of the cart mentioned by the project manager (who will bear the costs of the roadway renovation?). It is located at the bottom of a valley overhung by the street of Marsannay. In this respect, we can ask ourselves, among other things, the question of the height of the chimneys that will be erected: will it be determined by the immediate relief, which could bring them to the level of the houses on rue de Marsannay? Or will it be determined by the existence of these dwellings, in which case it is questionable whether it is urbanistically possible. Of course, no one doubts the harmlessness of systematic releases, but what about accidental releases? All pressurized systems operate with pressure relief valves and usually with expansion tanks… which are also equipped with the same valves. And it is difficult to move forward 

the idea that an explosion is better than a limited release. (This is the ecological argument that also governs the daily management of nuclear power). What are the standards? How can we guarantee their respect? How to punish violations? 

Secondly, the promoter talks about an innovative technique, pyrolysis, and the very limited nature of the nuisances. Have the engineers forgotten what they themselves call the « bathtub curve » ? The newer the technology and the more recent the installation, the greater the likelihood of incidents. This question is crucial when it comes to automated factories: who is still talking about hiring qualified and experienced personnel to control the technical processes? Secondly, the production, handling and storage of hydrocarbons entails risks of air, soil and river pollution and, more particularly, risks of fire or even explosion. The site of exploitation, located in the middle of the village, is not for all that easy of access. When will the report of the firefighters, who would be directly involved in stabilizing and securing an incident, be made public? 

Thirdly, the promoter presents itself as Recumas SPRL, located at 9 rue de l’usine in Mazy. However, Recumas SPRL does not exist. A company number was given orally (0418.071.879) and the company with this number is Carrosserie V.V. SPRL. Neither Recumas, nor Carrosserie V.V. are located at 9 rue de l’usine in Mazy: there is no registered office, nor any operating office at this address. Moreover, the corporate purpose of this limited liability company has remained unchanged since 1977; it is limited to the repair of vehicles and the sale of second-hand vehicles. If you look at it, Carrosserie V.V. is an empty shell, to the point of having been struck off the ECB’s books for not having filed annual accounts… since 2002. This deregistration was finally withdrawn following the filing, at the end of February 2016, of the 2013, 2014 and 2015 annual accounts, the content of which confirms by itself the total absence of activity of the company. This unannounced filing was done for the sole purpose of reselling the company’s VAT number to the developer. Although this technique is not illegal in the strict sense, it is not the recommended way to start a new business. It allows the transferee to escape several rules imposed when forming a new company, rules designed to protect the rights of third parties. This way, the buyer avoids the obligation to draw up a financial plan and the liability of the founders, and recovers a share capital that only exists on paper. In this case, the share capital amounts to 6,200 €, which is also lower than the legal minimum. Moreover, the tax losses of this SPRL make it fall under art. 332 of the Company Code, which could lead to its eventual dissolution. In short, what guarantees do we have that the promoter will give more respect to its environmental and health obligations than to the previous breaches? The icing on the cake (E122) is that this plant would only be designed to serve as a test, which could mean that it will be dismantled or abandoned when it has served its purpose and the Regional subsidies have been duly collected. What will happen to the site? Are we facing the programmed creation of a new polluted urban canker? More fundamentally, since the people who have presented themselves as responsible for the project are clearly neither the designers, experts in the chemical industry, nor private investors, would it not be appropriate to know on whose behalf they speak? 

In conclusion, if the sector plan is respected for the land in question, wouldn’t that simply mean that the sector plan is obsolete? The return of common sense in politics would be a strong signal to citizens a few months before the next elections. It is time for everyone to assume their responsibilities or, in a daze, to discover new ones.

Michel Weber and Ludovic Peters(1)

Notes et références
  1. Auteurs de « Quel avenir pour la Belgique fédérale ? », Kairos 13, avril/mai 2014, p. 17. 

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