Twenty years ago, I was a member of the Lowell Historic Board. During my tenure there, I gained great admiration for the wisdom and judgment of the representatives of the National Park Service who worked here in Lowell. I also learned then and through the years that many of the engineering accomplishments of our 19th Century predecessors here in Lowell were superior in functionality and reliability to much of what is designed today. For these and other reasons, I support the perpetuation of the existing Pawtucket Falls dam. The proponents of that position gained a valuable ally recently when the director of The International Committee for the Conservation of the Industrial Heritage released the following letter, which was first posted locally on Left in Lowell:

Secretary, Federal Energy Regulatory Commission July 1, 2011
888 First Street, NE
Washington, DC 20426

I write today as the President of The International Committee for the Conservation of the Industrial Heritage (TICCIH), the primary international organization concerned with industrial heritage. Among other activities, we advise UNESCO’s International Council on Monuments and Sites (ICOMOS) and the UNESCO World Heritage Committee, especially as regards World Heritage nominations of sites with industrial components. The matter of FERC’s finding of “no adverse effect” from proposed changes to the Pawtucket Dam in Lowell has recently come to my attention and I am compelled to comment, both as a practicing industrial archaeologist in the US and in my position as TICCIH President.

I am personally acquainted with Lowell and the Pawtucket Dam, having visited the site several times over the past three decades, and am well aware of the historical significance of this important site to the story of American and global industrialization. I have reviewed the extensive documentation on the FERC e-library site, including the EA and the comments of various entities and individuals. I will not repeat the complex arguments and interpretations here, but simply comment on the evidence from the perspective of an informed TICCIH representative.

The proposed undertaking, replacing the historic flashboard system with a pneumatic crest gate system, will certainly have a profound adverse effect on the integrity of the historic resources of the Lowell National Historical Park and the designated Landmark.

The Pawtucket Dam is a critical element in the ensemble of resources that make up the Landmark district. This is a waterpower and industrial production system, not a random collection of architectural elements, and the preservation of system elements is essential to maintaining the integrity of the site as a whole. The dam is certainly eligible for listing on the National Register in its own right, but in this case is included in the broader listing of the full District. While there may have been intrusions in the past, as your assessment notes, they have not had the degree of impact that this undertaking will impose. And of course, past sins should not be used to justify current acts.

The construction of the proposed pneumatic system will not only make an unwelcome visual intrusion, but will require addition of incompatible and inappropriate materials in the form of a concrete cap on the granite dam and an unsightly steel and rubber superstructure. This will substantially alter both the character and the appearance of the dam.

Furthermore, the historic flashboard system appears to have remained functional for decades; why not continue to use it? While the technical details are beyond my qualifications, it seems logical that engineered modifications in the steel pins could achieve the desired water control without massive changes in the dam. The operator’s justifications for change in the DEA are unconvincing.

The Lowell complex is globally recognized as an exemplar for the development of water powered industrial production. Its development signalled a fundamental shift in the technological and social organization of our nation from a predominant dependence on agrarian society to the rise of industrialized production. Lowell was a central force in proving that the concentration of capital and productive capacity, utilizing the abundant waterpower available at the fall line, could drive an immensely profitable enterprise. This model was repeated many times around the country and around the world, to profound effect.

Lowell remains one of the best preserved examples in the world of an early mill town, and its preservation is particularly significant since it was the first to combine the complex elements of technology, organization and natural setting to such great success. The recognition of Lowell as a prime example is signalled by its early designation as a National Historic Landmark, a recognition reserved for only the select few best historic sites in the country. As such, our system of laws requires that executive agencies and entities such as FERC advocate alternative actions that advocate preservation to the maximum extent possible. We have grown to expect nothing less. The opinions forwarded by your office up to this point fall far short of that expectation.

Finally, I must point out that the global community of scholars and officials concerned with industrial heritage will take great interest in the actions of FERC in this case. Lowell is renowned in the world as a key early industrial site, with the preservation and interpretation actions of the NPS and the State of Massachusetts standing as international examples. If the alteration of the Pawtucket Dam goes forward as proposed, this will have a profound negative impact on the integrity of the site as a whole. This action will certain disappoint many observers, and will likely jeopardize serious consideration of the site for listing in the World Heritage List, where site integrity is a key element for nomination.

I urge you to reverse the finding of “no adverse impact” and give further consideration to supporting the “no action” alternative in this case. I will be happy to elaborate on these comments if so desired.

Sincerely,
Patrick Martin, Ph.D.
TICCIH The International Committee for the Conservation of the Industrial Heritage