From: pmnehring@mail.co.marathon.wi.us
Sent: Thursday, August 10, 2006 7:39 PM
To: MarketingClaim
Subject: Docket No. LS-05-09 Grassfed Rule



Greetings,
First, I wish to express thanks to the USDA for tackling the contentious issue
of creating a "grass-fed standard"  Second, thank you for providing reasonable
time frame for making comments regarding your revised rule. 

I believe that the revised rule is a great improvement over the original rule
release several years ago.  It is a big step in the right direction.  However, I
am surprised at how long it took for the USDA to release the revised rule, and
would request that you speed up the process, as long delays are unecessary. 

I fully agree that the 99% forage diet is appropriate, as anything less allows
for too much fudging, cheating, and misinterpretations.  However, the rule
should specify what is allowed as forage, and what is not.  For instance,
grazing corn, without an ear, should be permissable, as the primary energy
source is the grass, not the seedhead.  However, corn silage with an ear is not
permissable.  It is debatable whether or not corn silage without an ear should
be allowed. 

Yet, stored forages should be allowed, as most of the country cannot graze
cattle year round, and there will be year round demand for locally produced
grassfed, fresh products.  My own consumers would rather purchase grassfed
products from stored forage fed livestock, in the winter, than conventional meat
and dairy products, if they have the choice.  And they would rather purchase
locally than fresh meats from other parts of the country or from other
countries. 

However, the standard, while allowing for feeding stored forages should address
where they are fed.  Feedlot feeding should be banned, and livestock should be
required to remain on pasture at all times, except during inclement weather, in
which a maximum time period of 30 days on a pad could be allowed.

Additionally, I believe that the use of synthetic hormones, and subtherapeutic
levels of antibiotics, in grass-fed  beef production should be banned.  These
are completely unecessary.  The use of antibiotics in feed is dangerous and may
ruin antibiotics use as tool to treat disease.  Additionally, consumers expect
that this product will not be contaminated by such products, and the standard
should address this. 

However, I do not believe that antibiotics should be banned outright, as they
are a valuable and humane treatment for disease.  While disease is rare in a
true grassfed system, we should be able to make use of antibiotics to save the
life of an animal.  Additionally, I view it as hypocritical to use antibiotics
and then have to ship an animal into conventional markets.  We either agree that
a treatment is useful for all animals or for none.  There is nothing wrong with
the appropriate use of antibiotics for treatment of disease, so I see no reason
not to allow for this in a grassfed standard. 

Sincerely,
Paul Nehring
Director of GrassWorks, Inc.  a non-profit devoted to advancing managed grazing
in Wisconsin.
Owner and operator of Newgrass Farms, LLC.  A grass-fed beef enterprise.