In the EA, please provide a full and fair accounting of the financial costs of removing the overstory versus leaving it uncut. However, on page 5 of the scoping letter you state that 4 to 8 northern hardwood trees would be left per acre and 12 to 18 red oak trees would be left per acre. Thus, it would seem that even more northern hardwood overstory trees could be left without detriment to the understory. In the scoping letter you suggest that many of the overstory trees are dying and removal is needed to salvage them. Crown dieback is being seen, in maples especially, throughout Vermont and New England, and is not a justification for logging.
Trees experiencing dieback can live for many more decades.
From these field observations of the GMNF it would seem that removal of the overstory is not needed for the young oak seedlings to flourish. In fact, removal of the oak overstory seems to present a greater loss and risk than it does a benefit on a forest where oak regeneration is difficult. Please describe the ecological, economic and social implications of removing the rare and ecologically important red oak overstory trees on a forest where regenerating oak trees is acknowledged as risky and difficult. Myotis sodalis are known to require large, old trees for summer roosting and maternity sites, and are known to frequent the same trees and areas repeatedly. Eliminating all or nearly all of the large mature trees from an area, as is done by clearcutting and overstory removals, could eliminate this essential habitat for the bats.