Organe Institute has recently submitted responses to public hearings regarding proposed amendments to Danish regulations related with livestock manure. Amendments were proposed to the executive order on environmental permitting of facilities for rearing of pigs and poultry. 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, which has not had 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).

The law governing the mentioned executive order was likewise proposed to be changed to make use of the LSU, and we therefore submitted a response much using the same wording as for our response to the draft amendments of the executive order. However, we added some exemplification, underlining the skewed effect the proposed amendments would have. Using the proposed LSU coefficients would mean a threshold for required environmental permitting for sow/piglet production that would be five times higher with respect to N + P in the manure ex animal than using the same LSU-based threshold for a slaughter pig production. We also recommended a re-introduction of the "Animal Unit" that was used for agro-environmental regulation in Denmark from 1991 to 2015. The Animal Unit was popular, effective and pedagogic at the same time, and could be re-defined as for instance 100 kg N + P in manure ex animal. See our hearing response (in Danish).

Thirdly, we have responded to draft amendments of phosphorus fertilisation regulations. We see the proposed amendments as continuing a practice of ineffective and unnecessary complicated regulation, that is out of sync with both EU, International and Danish policies. We recommend using crop phosphorus fertilisation needs as already specified in official Danish guidelines, and furthermore to give incentives for a total P balance of 0 kg over a five-year period. This would be in line with regulations already introduced in Sweden, as well as HELCOM guidelines. See our hearing response (in Danish).