July 7, 2011
Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
RE:
Project No. 2790-055 – Pawtucket Falls Dam
Dear Secretary,
On behalf of Preservation Massachusetts, I wish to submit commentary on the draft EA for the Lowell
Hydroelectric Project (number 2790-055) and its proposed effects on the Pawtucket Falls Dam. Founded
in 1985, Preservation Massachusetts is the statewide non-profit organization that actively promotes the
preservation of historic buildings and landscapes as a positive force for economic development and the
retention of community character. This organization often is asked to submit our thoughts and
commentary on matters as they affect historic resources and preservation efforts in Massachusetts.
We first became aware of the Pawtucket Dam when it was nominated to our Massachusetts Most
Endangered Historic Resources List. Since 1993, this advocacy and education program helps focus
statewide attention on the plight of resources facing a variety of threats, from demolition, insensitive
public policy, development, etc. Concerned citizens from Lowell submitted a nomination to this
program in response to the Lowell Hydroelectric project proposed by Boot Hydropower, Inc. As it
stands, this project would irreversibly damage an extremely historic resource in a community that has
accomplished so much in terms of historic preservation.
In light of the historic significance of the Pawtucket Dam and the irreversible damage that could
potentially be inflicted through the current proposed plan, Preservation Massachusetts has named the
Pawtucket Dam to our 2010 Most Endangered Historic Resources List. This nomination was reviewed
and the selection made by a committee of over 30 professionals from the fields of historic preservation,
architecture, history, non-profit leadership, community development and more. The purpose of the
program is to bring a greater awareness about the importance of this historic resource and beginning a
dialogue to identify more sensitive options the treatment of the dam in the hydroelectric project.
In reviewing the draft EA dated June 10, 2011, our organization has serious concerns about the findings
regarding the historic significance of the dam, especially the “no adverse impact” decision. The
statement is egregious, along with the belief that the dam is not individually significant because it is not
individually listed on the National Register of Historic Places. Findings and arguments to the contrary
have been submitted to your Commission by the foremost preservation offices in the state and nation,
including the Massachusetts Historical Commission and State Historic Preservation Officer, the National
Park Service and the Advisory Council on Historic Preservation. As a partner and colleague organization,
Preservation Massachusetts stands in full support of their position that the installation of a crest gate
system would have a serious adverse impact on the historic integrity of not only the Pawtucket Dam
itself, but the entire historic district and National Park.
It also appears from the draft EA that the comments of these agencies have not been taken into
consideration, including a directive from the Massachusetts SHPO’s office dated May, 2011, that FERC
contact the Keeper of the National Register regarding the Pawtucket Dam. To the best of our
knowledge, this has not happened as of yet. We urge your Commission to take full regard of the input
and comments being submitted by the historic preservation and cultural heritage organizations and
others who are extremely concerned about the impact of the proposed project and its ramifications for
similar projects in the future.
We believe there is still opportunity to collaborate on a project that would maintain the dam’s historic
features and be more in harmony with proposed improvement plans for this area of Lowell. We urge
you to once again consider the impact the Lowell Hydroelectric Project will have on this extremely
important historic resource in the middle of a city that has experienced a renaissance based on
embracing preservation and history.
I thank you for the opportunity to comment and urge you consider the impact this project will have on a
resource that has tremendous significance not only to Lowell, but all of Massachusetts.
Sincerely,
James W. Igoe
President
cc:
Peter Aucella, Assistant Superintendent, Lowell National Historical Park
Steven Stowell, Administrator, Lowell Historic Board
Brona Simon, Massachusetts State Historic Preservation Officer
Carol Shull, Keeper of the National Register of Historic Places
John Fowler, Advisory Council on Historic Preservation
Rebecca Williams, Northeast Regional Office of the National Trust for Historic Preservation