Docket No. LS-05-09, Grass (Forage) Fed RuminantsFrom: Cropper, James -NRCS
Sent: Friday, August 04, 2006 5:45 PM
To: MarketingClaim
Cc: Ogles, Kevin -NRCS; Hall, Michael -NRCS; Adams, Carolyn -NRCS
Subject: Docket No. LS-05-09, Grass (Forage) Fed Ruminants



Dear Agricultural Marketing Service Officials,

Thanks for the opportunity to enter comments into the record concerning the rule
on Grass (Forage) Fed Ruminants.  I have attached my comments to this email for
your consideration in preparing the final rule.  I think it is very important
that we also consider the water quality implications as well as good animal
nutrition in the final rule.  99% of the diet coming from grass or forage is too
high to have a balanced ration that provides good weight gains and also reduces
nitrogen losses to the environment.

Jim Cropper

James B. Cropper
Forage Management Specialist
USDA-NRCS East National Technology Support Center
200 E. Northwood Street, Suite 410
Greensboro, NC 27401
(336) 370-3346
Email: james.cropper@gnb.usda.gov

Grass-fedrulecomments.doc

Docket Number LS-05-09:  United States Standard for Livestock and Meat Marketing
Claim, Grass (Forage) Fed Claim Comments

Stating that 99% of the energy source for the lifetime of the ruminant specie
shall be from grass or forage is going too far in the other direction from the
original proposed value of 80%.  Supplemental feeding of ruminants that are on
pasture or being fed stored forages during the pasture dormancy period is
essential practice for both profitability and water quality concerns. 
Supplementing a ruminant that is on a very high forage diet, pasture or stored -
cured or fermented forage, is very important to balancing the ration given the
ruminant.  Better weight gains can be had by feeding ruminants supplements that
have more rumen undegradable (bypass) protein or more energy to better utilize
the rumen degradable protein than any forage crop, standing or stored, has. 
When the additional energy (carbohydrate) is supplied to their diet, the rumen
degradable protein is better utilized by the rumen bacteria.  Less of this
protein is wasted and less is excreted as uric acid in their urine.  When uric
acid comes in contact with the soil it becomes hydrolyzed into ammonia which
either volatilizes, becoming an air borne pollutant, or nitrifies, becoming a
water pollutant source.  Urine spots on pastures with high concentrations of
nitrate are subject to leaching and runoff.  This additional nitrogen in the
water can degrade receiving waters that are nitrogen limited, or cause high
levels of nitrate to be found in wells or streams.  Newer research would
indicate that grass fed animals can be fed 0.3% of their body weight in grain to
improve weight gain and cut down on inefficient use of the protein often found
in high quality pastures.  On low quality pastures, the amount of
supplementation might actually have to increase more, perhaps to 0.5% of their
body weight.  Since grass fed weight gaining ruminants generally consume dry
matter at a rate of 3.0% of their body weight, a more realistic percentage
figure for energy source coming from grass or forage would 90%, 0.3%÷3.0%.

In order to forestall some people from feeding the 10% concentrate all at once
near the end of the life of the slaughter animal, the wording must be carefully
crafted to say that at no time after weaning will the daily ration be less than
90% grass or forage.  There will be criticism if the rule gets very long or
complicated, but if left too simple, it becomes very easy to corrupt its intent.

Corn silage is forage technically.  It will easily run more than 10% grain
unless it failed to set many full ears.  It then by its very nature could not be
used as the whole source of forage.  It, if used, would have to be diluted
considerably by hay crop silage or haylage, or pasture.  There would be some
need to clarify corn silage use perhaps just to forestall some people from
making unwarranted assumptions that the grain in it would not count.

The rule indicates to me that the only forbs to meet the letter of the rule
would be legumes and Brassicas.  Dandelions, plantains, and many other weedy
forbs are routinely grazed and need not be eradicated.  It may be better to
indicate that legumes and Brassicas are only examples of forbs, not the complete
list of acceptable forbs.

The title of the rule should also make clear that this applies only to grass or
forage fed ruminants.  Even though the rule itself says in the text that it
applies to ruminants only, it would be better if it was stated up-front in the
title and then again under Claim and Standard, Grass (Forage) Fed Ruminants. 
Chickens and pigs would need a separate rule to be classified as being “on
grass”, “free range”, or “pastured”.

James B. Cropper, Forage Management Specialist
USDA-NRCS, East National Technology Support Center
200 E. Northwood Street, Suite 410, Greensboro, NC 27401