Organe Institute has delivered a response to a public hearing in Denmark regarding proposed amendments to the Danish livestock approval executive order. The amendments aim at implementing updates of EU's Industrial Emissions Directive (EU/2024/1785). The essence of our response is that environmental regulation of facilities for livestock production, including production size thresholds, should be based on the amount of nitrogen (N) and phosphorus (P) in manures ex animal, whereas the use of the Livestock Standard Unit (LSU) is anachronistic and make environmental regulation arbitrary. The LSU is a livestock grazing equivalent, introduced in 1966 and not having coefficients updated since then despite substantial change of production systems, productivity levels and feed intensities in the meantime. The LSU has no, whatsoever, relation to the environmental load of livestock farming. See our entire consultation response (in Danish).