From: dwd@dwdlonghorns.com Sent: Wednesday, June 28, 2006 9:38 PM To: MarketingClaim Subject: Grassfed Claim, Docket No. LS-05-09 Thank you for the opportunity to express my view concerning the USDA Grassfed Marketing Claim. I have two concerns regarding the proposed standard. The first is the definition of "forage". I support language in the standard that would prohibit the feeding of grain silage with a fully developed seed head. My second concern, and my greatest concern, is that the proposed standard does not prohibit the feeding of grassfed animals in confinement. It is my opinion that the term "grassfed" is synonymous with non-confinement. I run a grassfed beef operation in Central Texas that sells to restaurants, health food stores and directly to the public. It is my experience that ALL of my customers think of grassfed as never being fed in confinement. If this grassfed standard is allowed without prohibiting confinement feeding I believe it will defeat the USDA's original intent in creating this standard by causing confusion among consumers and denying grassfed producers the opportunity to fully distinguish their products in the marketplace; as it will not accurately describe the production methods of most grassfed producers. USDA's "Notice and request for comments" states "While there is a synergistic nature to grass feeding and free range conditions, AMS has determined it is preferable to keep the terminology separate and develop two distinct standards for both grass (forage) fed and free range claims, particularly in view of possible distinctions in their energy sources. Granted, most grass (forage) fed livestock will also qualify as free range livestock (not fed in confinement); however, not all free range livestock will receive their entire energy source from grass or forage." This implies that feeding of grain will be allowed in the "free range" standard. If indeed the "grassfed" claim does not forbid confinement feeding and the later 'free range" standard does not forbid feeding of grain then there will be no standard or combination of standards that accurately describes natural forage fed ruminants with no confinement which is the common practice of most grassfed producers and what the public demands and expects when they purchase grassfed products. I am very concerned that if this standard does not prohibit confinement it will open the doors for bastardization of the term "grassfed" allowing industrial confinement feedlots to label their products "grassfed." We will soon see feedlots that merely change from grain to forage and re-label their product as "grassfed"; this is not what the public wants or expects from "grassfed" products and does not accurately describe the production methods used by todays grassfed producers. Just go to any Farmer's Market and ask the customers what they think "grassfed" means. Don Davis Bandera Grassland 3361 C.R. 211 Hondo, Texas 78861 830/562-2333 dwd@dwdlonghorns.com