I think it has a tendency to be tougher because of less fat marbling it. You can compensate by cooking it lower/shorter (for grill) and lower/longer (for stew/braise) than grain fed.
And then just use really sharp steak knives. I've noticed my judgment on how tough something is tends to be heavily influenced by the sharpness of the knife I cut it with
Zone diet on and off for several years....worked, but too much focus on exact meal composition
Primal since July 2010...skinniest I've ever been and the least stressed about food