Comment submitted by Joel Levie, Levie Apiaries

Dear Office of Pesticide Programs, I am very concerned about the product Movento. I have been a beekeeper for over 30 years. Recently it has come to my attention that serious irregularities have occurred with the registration of Movento. EPA scientists have indicated to me that they were not allowed to validate the statistical results of the ecological effects assessment for Movento. It was explained to me by these same scientists that the ecological effects assessment which was preformed by Austria relied on only summaries of industry generated data. Independent verification for this data has not been preformed. Bee larvae and bird data needs at a minimum to be statistically validated. Page 11 of the Enviromental Risk Assessment indicates that summaries of studies were utilized. Summaries of data generated by industry! EPA scientists are uncomfortable with this data, and independent verification under these circumstances is essential. Until such time as this ecological effects data provided by Austria can be independently verified registration or even conditional registration should not be allowed for this product in the United States. I am outraged that such information was taken at face value. Honeybees are in a state of crisis in this country. Please, go the extra mile and at least preform the verifications necessary, as EPA scientists are requesting, to assess the integrity of this Austrian data. Joel Levie