August 9, 2006

Martin E. O'Conner
Chief, Standardization Branch
AMS, USDA
Washington DC 20250

RE: Docket, LS-05-09

I would like to thank the USDA for their work on coming up with a standard for
grassfed. The change from 80% to 99% is to be applauded, though I feel 100%
would be eaiser to verify. I would like consideration of allowing those that can
verify 100% to claim 100% on their label.
I would also like you to consider allowing operations that are organic or humane
certified to be allowed to have their product certified through the agency that
they are already using.
I do believe that you should allow verifiable health claims, such as low fat, or
future verifiable health claims, such as CLA content. Inserting language to
allow future verifiable health claims now, will save future delays similar to
what we have experienced getting a grassfed standard.
I  would also like to see language added that will not allow producers to
included the term ''grassfed'' in thier company name unles they are selling
certfied product. It is my understanding that there is precedent for this in the
organic standards. If this provision is not added ranches will just change their
ranch name to inluded the word grassfed instead of going through the paper work
of verification.
Another item is an exemption for small or startup ranchers. The organic
standards allow an exemption for sales under $5000. This figure would be to low
for meat sales... $5000 is a lot of tomatoes, but equals less than 2 processed
beeves or bison. Perhaps $30,000, as this would allow most small marketers that
sell at farmers markets or directly from their ranch. The consumer would be
protected because they would be buying directly from the producer, and could
easily visit their ranch. 
 Last, but most important, it is imperative that you include language that
doesn't allow confinement for other than roundups, shipping, or weaning. The AGA
standard of ''Animals must not be allowed in pens or other confined areas where
forage growth is not sustained over the entire paddock during the normal growing
season.''

Respectfully submitted
Robert Long
Flintrock Bison Ranch
Halltown MO