Appendix A_Trolley Platforms PEPC 120536_Signed.pdf

National Park Service U.S. Department of the Interior

Lowell National Historical Park

Date: 02/28/2025

Letter of Compliance Completion

To: George Little / Pat Egan / Tim Croteau

From: Juliet Galonska

Subject: NEPA and NHPA Clearance: ATS-Rehabilitate Trolley System- Replace Five Track Platforms and One Track Crossing and Associated Ties (PEPC: 120536)(PMIS: 313370)

NEPA and NHPA Compliance Complete. For complete compliance information see PEPC Project 120536.

The Superintendent and Interdisciplinary team have reviewed the scope of work and supporting documentation provided in the Planning, Environment, and Public Comment (PEPC) system, and all applicable associated compliance documentation and consultation (e.g. National Environmental Policy Act, National Historic Preservation Act, Endangered Species Act, Clean Water Act, Clean Air Act, Wilderness Act, Tribal consultation under EO13175, and other related laws and policies).

The subject proposed project/action(s), therefore, is/are now cleared for all compliance requirements. Project plans and specifications are approved, project funds may be released, and construction and/or project implementation can commence with the following mitigations and conditions/stipulations.

There are no required mitigations identified.

NHPA Recommendations for Conditions or Stipulations:

1. Moody Street Feeder - contract language shall be added to solicitation limiting selective demo by chipping guns in lieu jack hammering to limit vibrations with penstocks below grade.

2. Moody Street Feeder - contract language in solicitation for required GC vibration monitoring and crack monitoring at gatehouse to be coordinated with Historical Architect and COR. NO GROUND DISTURBANCE.

3. Tremont Gatehouse - NO ground disturbance-replace in kind structural composite decking and framing.

4. Rubber track insert at High School Crossing

5. Solicitation shall include "structural composite" for decking and sub-frame, design basis, "PolyForce by Tangent Industries"; https://tangentmaterials.com/

Superintendent: _______________________________________ Date:__________________________ Juliet Galonska

Lowell National Historical Park Date: 02/28/2025

Categorical Exclusion Documentation Form (CE Form)

Project: ATS-Rehabilitate Trolley System- Replace Five Track Platforms and One Track Crossing and Associated Ties PEPC Project Number: 120536 Description of Action (Project Description):

Lowell National Historical Park maintains an existing alternative transportation trolley system within the downtown Historic District in Lowell, MA. The system maintains an approximately 1.5 mile track system with multiple platform stops for Park visitors.

Critical to visitor experience and visitor and public safety is maintaining trolley station platforms, adjacent plaza spaces, and associated track ties in compliance with code and accessibility standards and free from surface hazards.

The existing stops consist of composite decking on pressure treated sub-framing and are directly adjacent to the track lines. The existing track platforms have reached their cyclic lifespan and are degrading resulting in safety and accessibility hazards and barriers.

The four subject stations that are included in the proposed project are: Tremont Station (1470 SF of Structural Composite Decking) - that serves the Suffolk Mill Turbine Exhibit at Wannalancit Mills that serves general Park visitors and school group tours; Mack Plaza Station (8372 SF of Structural Composite Decking with 864 SF of Cast-in-place Concrete) that serves the Park Visitor Center; Swamp Locks Station (400 SF of Structural Composite Decking) that serves Swamp Locks Gatehouse and Park canal boat tours launch site; Moody Street Feeder Gatehouse (500 SF of Structural Composite Decking and 200 SF of Cast-in-place Concrete) that serves interpretation and educational programs at the gatehouse.

A fifth area, a track crossing, at Lowell High School (176 SF of Structural Composite decking and rubber track insert) that serves students and staff and general public use of the Ayotte Parking Garage, will be installed by Park Facilities Maintenance staff.

The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Structural Composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing.

These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not involve excavation that removes material below existing grade. GROUND DISTURBANCE WILL NOT BE

REQUIRED TO UNDERTAKE THE PROPOSED WORK.

Project Locations:

Location County: Middlesex State: MA

There are no required mitigations identified.

CE Citation: 3.3.C.4 Routine maintenance and repairs to cultural resource sites, structures, utilities and grounds under an approved Historic Structures Preservation Guide or Cyclic Maintenance Guide; or if the action would not adversely affect the cultural resource.

CE Justification:

3.3.C.4 Routine maintenance and repairs to cultural resource sites, structures, utilities and grounds under an approved Historic Structures Preservation Guide or Cyclic Maintenance Guide; or if the action would not adversely affect the cultural resource. The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Trex composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing. These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement. The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not involve excavation that removes material below existing grade. GROUND DISTURBANCE WILL NOT BE REQUIRED TO UNDERTAKE THE PROPOSED WORK. Stipulations from NHPS Review: 1. Moody Street Feeder - contract language shall be added to solicitation limiting selective demo by chipping guns in lieu jack hammering to limit vibrations with penstocks below grade. 2. Moody Street Feeder - contract language in solicitation for required GC vibration monitoring and crack monitoring at gatehouse to be coordinated with Historical Architect and COR. NO GROUND DISTURBANCE. 3. Tremont Gatehouse - NO ground disturbance-replace in kind structural composite decking and framing. 4. Rubber track insert at High School Crossing 5. Solicitation shall include "structural composite" for decking and sub-frame, design basis, "PolyForce by Tangent Industries"; https://tangentmaterials.com/

Decision: I find that the action fits within the categorical exclusion above. Therefore, I am categorically excluding the described project from further NEPA analysis. No extraordinary circumstances apply.

Executive Order 14154, Unleashing American Energy (Jan. 20, 2025), and a Presidential Memorandum, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025), require the Department to strictly adhere to the National Environmental Policy Act (NEPA), 42 U.S.C. §§ 4321 et seq. Further, such Order and Memorandum repeal Executive Orders 12898 (Feb. 11, 1994) and 14096 (Apr. 21, 2023). Because Executive Orders 12898 and 14096 have been repealed, complying with such Orders is a legal impossibility. The NPS verifies that it has complied with the requirements of NEPA, including the Department's regulations and procedures implementing NEPA at 43 C.F.R. Part 46 and Part 516 of the Departmental Manual, consistent with the President's January 2025 Order and Memorandum

Signature

Superintendent: Date:

Extraordinary Circumstances:

If implemented, would the proposal... Yes/No Explanation A. Have significant impacts on public health or safety? No No-will remove accessibility and life safety barriers

B. Have significant impacts on such natural resources and unique geographic characteristics as historic or cultural resources; park, recreation, or refuge lands;

wilderness areas; wild or scenic rivers; national natural landmarks; sole or principal drinking water aquifers; prime farmlands; wetlands (Executive Order 11990);

floodplains (Executive Order 11988); national monuments; migratory birds; and other ecologically significant or critical areas?

No NO

C. Have highly controversial environmental effects or involve unresolved conflicts concerning alternative uses of available resources (NEPA section 102(2)(E))?

No NO

D. Have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks?

No NO

E. Establish a precedent for future action or represent a decision in principle about future actions with potentially significant environmental effects?

No NO

F. Have a direct relationship to other actions with individually insignificant, but cumulatively significant, environmental effects?

No NO

G. Have significant impacts on properties listed or eligible for listing on the National Register of Historic Places, as determined by either the bureau or office?

No NO

H. Have significant impacts on species listed or proposed to be listed on the List of Endangered or Threatened Species, or have significant impacts on designated Critical Habitat for these species?

No NO

I. Violate a federal, state, local or tribal law or requirement imposed for the protection of the environment?

No NO

J. Have a disproportionately high and adverse effect on low income or minority populations (EO 12898)?

No NO. The President has revoked Executive Order 12898.

K. Limit access to and ceremonial use of Indian sacred sites on federal lands by Indian religious practitioners or adversely affect the physical integrity of such sacred sites (EO 130007)?

No NO

L. Contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species known to occur in the area or actions that may promote the introduction, growth, or expansion of the range of such species (Federal Noxious Weed Control Act and Executive Order 13112)?

No NO

Lowell National Historical Park

Date: 02/28/2025

ASSESSMENT OF ACTIONS HAVING AN EFFECT ON

HISTORIC PROPERTIES

A. DESCRIPTION OF UNDERTAKING

1. Park: Lowell National Historical Park

2. Project Description:

Project Name: ATS-Rehabilitate Trolley System- Replace Five Track Platforms and One Track Crossing and Associated Ties Prepared by: David Lieb Date Prepared: 01/30/2025 Telephone:

PEPC Project Number: 120536 Locations:

County, State: Middlesex, MA Describe project:

Lowell National Historical Park maintains an existing alternative transportation trolley system within the downtown Historic District in Lowell, MA. The system maintains an approximately 1.5 mile track system with multiple platform stops for Park visitors.

Critical to visitor experience and visitor and public safety is maintaining trolley station platforms, adjacent plaza spaces, and associated track ties in compliance with code and accessibility standards and free from surface hazards.

The existing stops consist of composite decking on pressure treated sub-framing and are directly adjacent to the track lines. The existing track platforms have reached their cyclic lifespan and are degrading resulting in safety and accessibility hazards and barriers.

The four subject stations that are included in the proposed project are: Tremont Station (1470 SF of Structural Composite Decking) - that serves the Suffolk Mill Turbine Exhibit at Wannalancit Mills that serves general Park visitors and school group tours; Mack Plaza Station (8372 SF of Structural Composite Decking with 864 SF of Cast-in-place Concrete) that serves the Park Visitor Center; Swamp Locks Station (400 SF of Structural Composite Decking) that serves Swamp Locks Gatehouse and Park canal boat tours launch site; Moody Street Feeder Gatehouse (500 SF of Structural Composite Decking and 200 SF of Cast-in-place Concrete) that serves interpretation and educational programs at the gatehouse.

A fifth area, a track crossing, at Lowell High School (176 SF of Structural Composite decking and rubber track insert) that serves students and staff and general public use of the Ayotte Parking Garage, will be installed by Park Facilities Maintenance staff.

The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Structural Composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing.

These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not

Area of potential effects (as defined in 36 CFR 800.16[d])

1. Moody Street Feeder Gatehouse (Merrimack Gatehouse), CRIS-HS # 022695, LOWE, 18543, Meets NR Criterion A - for its association with industrial history. MACRIS LOW.934 MOODY STREET FEEDER, existing sub-surface penstock tunnels that connect from Merrimack Canal to Moody Street, Western Canal

2. Tremont Station, LOWE, 243193 TROLLEY PLATFORM, existing sub-surface penstocks at Western Canal

3. Mack Plaza, LOWE, 116772,

4. Swamp Locks Station, LOWE, 243193 TROLLEY PLATFORM

5. Lowell High School Station, LOWE, 243193 TROLLEY PLATFORM

**MACRIS LOW C LOWELL NATIONAL HISTORICAL PARK 0931995, MACRIS LOWE C Locks and Canals Historic District 08_13_1976

REPLACE-IN-KIND, NO GROUND DISTURBANCE

3. Has the area of potential effects been surveyed to identify historic properties?

No

X Yes

Source or reference: 1980 LOWE HSR Complexes and Locks, 1979 LOWE HSR Moody Street Feeder

4. Potentially Affected Resource(s):

Archeological Resources Present: No

Historical Structures/Resources Present: Yes

Historical Structures/Resources Notes: 1. Moody Street Feeder Gatehouse (Merrimack Gatehouse), CRIS-HS # 022695, LOWE, 18543, Meets NR Criterion A - for its association with industrial history. MACRIS LOW.934

MOODY STREET FEEDER

1A. 1980 LOWE HSR Complexes and Locks, 1979 LOWE HSR Moody Street Feeder

Cultural Landscapes Present: Yes

Cultural Landscapes Notes: 1980 LOWE D-3 Cultural Resources Inventory

Ethnographic Resources Present: No

5. The proposed action will: (check as many as apply)

No Destroy, remove, or alter features/elements from a historic structure

Yes Replace historic features/elements in kind

No Add non-historic features/elements to a historic structure

No Alter or remove features/elements of a historic setting or environment (inc. terrain)

No Add non-historic features/elements (inc. visual, audible, or atmospheric) to a historic setting or cultural landscape

No Disturb, destroy, or make archeological resources inaccessible

No Disturb, destroy, or make ethnographic resources inaccessible>

No Potentially affect presently unidentified cultural resources

No Begin or contribute to deterioration of historic features, terrain, setting, landscape elements, or archeological or ethnographic resources

No Involve a real property transaction (exchange, sale, or lease of land or structures)

Other (please specify):

6. Supporting Study Data:

(Attach if feasible; if action is in a plan, EA or EIS, give name and project or page number.)

B. REVIEWS BY CULTURAL RESOURCE SPECIALISTS

The park 106 coordinator requested review by the park's cultural resource specialist/advisors as indicated by check-off boxes or as follows:

[ X ] 106 Advisor Name: David Lieb Date: 01/30/2025 Comments: NO ADVERSE EFFECT The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Trex composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing.

These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not involve excavation that removes material below existing grade. GROUND DISTURBANCE WILL NOT BE

REQUIRED TO UNDERTAKE THE PROPOSED WORK.

Check if project does not involve ground disturbance [ X ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Recommendations for conditions or stipulations: 1. Moody Street Feeder - contract language shall be added to solicitation limiting selective demo by chipping guns in lieu jack hammering to limit vibrations with penstocks below grade. 2. Moody Street Feeder - contract language in solicitation for required GC vibration monitoring and crack monitoring at gatehouse to be coordinated with Historical Architect and COR. NO GROUND DISTURBANCE. 3. Tremont Gatehouse - NO ground disturbance-replace in kind structural composite decking and framing. 4. Rubber track insert at High School Crossing 5. Solicitation shall include "structural composite" for decking and sub-frame, design basis, "PolyForce by Tangent Industries"; https://tangentmaterials.com/

Doc Method: Streamlined Review Activity:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks

3. Repair/Resurfacing/Removal of Existing, Roads, Trails and Parking Areas

13. Meeting Accessibility Standards in Historic Structures and Cultural Landscapes

[ X ] Historical Architect Name: David Lieb Date: 01/30/2025 Comments: NO ADVERSE EFFECT The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Trex composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing.

These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not involve excavation that removes material below existing grade. GROUND DISTURBANCE WILL NOT BE

REQUIRED TO UNDERTAKE THE PROPOSED WORK.

Check if project does not involve ground disturbance [ X ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Recommendations for conditions or stipulations: 1. Moody Street Feeder - contract language shall be added to solicitation limiting selective demo by chipping guns in lieu jack hammering to limit vibrations with penstocks below grade. 2. Moody Street Feeder - contract language in solicitation for required GC vibration monitoring and crack monitoring at gatehouse to be coordinated with Historical Architect and COR. NO GROUND DISTURBANCE. 3. Tremont Gatehouse - NO ground disturbance-replace in kind structural composite decking and framing. 4. Rubber track insert at High School Crossing 5. Solicitation shall include "structural composite" for decking and sub-frame, design basis, "PolyForce by Tangent Industries"; https://tangentmaterials.com/

Doc Method: Streamlined Review Activity:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks

[ X ] FACILITY SUPERVISOR FOR Trolley System Name: Pat Egan Date: 01/28/2025 Comments: 1. Straight deferred maintenance activity-no adverse effect.

2. Potential modification to contract to stabilize existing locomotive (pullman car and caboose) - safety concern.

Check if project does not involve ground disturbance [ X ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Recommendations for conditions or stipulations: 1. Power lock out tag out - trolley catenary. 2. Work on NPS property - follow standard safety procedures and protocols. 3. Volpe to review and GC safety plans

Doc Method: Streamlined Review Activity:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks

[ X ] FM Park Architect Name: George Little Date: 02/04/2025

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Recommendations for conditions or stipulations: 1. Site visits during demolition to verify grade conditions and vibration concerns.

Doc Method: Streamlined Review Activity:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks

No Reviews From: Curator, Archeologist, Historian, Anthropologist, Historical Landscape Architect

C. PARK SECTION 106 COORDINATOR'S REVIEW AND RECOMMENDATIONS

1. Assessment of Effect:

No Potential to Cause Effects

No Historic Properties Affected

X No Adverse Effect

Adverse Effect

2. Documentation Method:

[ ] Standard 36 CFR Part 800 Consultation Further consultation under 36 CFR Part 800 is needed.

[ X ] Streamlined Review Under the 2008 Servicewide Programmatic Agreement (PA) The above action meets all conditions for a streamlined review under section III of the 2008 Servicewide PA for Section 106 compliance.

Applicable Activities:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks.

3. Repair/Resurfacing/Removal of Existing, Roads, Trails and Parking Areas.

13. Meeting Accessibility Standards in Historic Structures and Cultural Landscapes .

[ ] Program Comment on Stewardship and Management of National Park Service Mission 66-Era Facilities (1945-1972) The above action meets all of the requirements of this Program Comment for Section 106 compliance and required documents have been uploaded.

[ ] Undertaking Related to Park Specific or Another Agreement The proposed undertaking is covered for Section 106 purposes under another document such as a park, region or statewide agreement established in accord with 36 CFR 800.7 or 36 CFR 800.14.

3. Consultation Information

SHPO Required:

SHPO Sent:

SHPO Received:

THPO Required: No THPO Sent:

THPO Received:

SHPO/THPO Notes:

Advisory Council Participating: No Advisory Council Notes:

Additional Consulting Parties: No

4. Stipulations and Conditions: Following are listed any stipulations or conditions necessary to ensure that the assessment of effect above is consistent with 36 CFR Part 800 criteria of effect or to avoid or reduce potential adverse effects.

1. Moody Street Feeder - contract language shall be added to solicitation limiting selective demo by chipping guns in lieu jack hammering to limit vibrations with penstocks below grade. 2. Moody Street Feeder -contract language in solicitation for required GC vibration monitoring and crack monitoring at gatehouse to be coordinated with Historical Architect and COR. NO GROUND DISTURBANCE. 3. Tremont Gatehouse

- NO ground disturbance-replace in kind structural composite decking and framing. 4. Rubber track insert at High School Crossing 5. Solicitation shall include "structural composite" for decking and sub-frame, design basis, "PolyForce by Tangent Industries"; https://tangentmaterials.com/

5. Mitigations/Treatment Measures: Measures to prevent or minimize loss or impairment of historic/prehistoric properties: (Remember that setting, location, and use may be relevant.)

No Assessment of Effect mitigations identified.

6. Assessment of Effect Notes:

NO ADVERSE EFFECT

The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Trex composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing.

These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not involve excavation that removes material below existing grade. GROUND DISTURBANCE WILL NOT BE

REQUIRED TO UNDERTAKE THE PROPOSED WORK.

Track and platform areas have been previously disturbed when the system was first installed. Archeological investigation was not deemed necessary as significant ground disturbance was not required for first installation of the alternative transportation system.

D. RECOMMENDED BY PARK SECTION 106 COORDINATOR:

Compliance Specialist:

NHPA Specialist

David Lieb

Date:

E. SUPERINTENDENT'S APPROVAL

The proposed work conforms to the NPS Management Policies and Cultural Resource Management Guideline, and I have reviewed and approve the recommendations, stipulations, or conditions noted in Section C of this form.

Signature

Superintendent:

Date:

Basic Information Form

Park Name: Lowell NHP

PEPC Project ID: 120536

Other Project ID:

PMIS ID: 313370

Project Status: Proposed

Compliance Status: Closed Complete

Sensitive: No

Project Target Start: 06/14/2024

Project Creation Date: 12/11/2023

Project Title: ATS-Rehabilitate Trolley System- Replace Five Track Platforms and One Track Crossing and Associated Ties

Secondary Title:

Project Description: Lowell National Historical Park maintains an existing alternative transportation trolley system within the downtown Historic District in Lowell, MA. The system maintains an approximately 1.5 mile track system with multiple platform stops for Park visitors.

Critical to visitor experience and visitor and public safety is maintaining trolley station platforms, adjacent plaza spaces, and associated track ties in compliance with code and accessibility standards and free from surface hazards.

The existing stops consist of composite decking on pressure treated sub-framing and are directly adjacent to the track lines. The existing track platforms have reached their cyclic lifespan and are degrading resulting in safety and accessibility hazards and barriers.

The four subject stations that are included in the proposed project are: Tremont Station (1470 SF of Structural Composite Decking) - that serves the Suffolk Mill Turbine Exhibit at Wannalancit Mills that serves general Park visitors and school group tours; Mack Plaza Station (8372 SF of Structural Composite Decking with 864 SF of Cast-in-place Concrete) that serves the Park Visitor Center; Swamp Locks Station (400 SF of Structural Composite Decking) that serves Swamp Locks Gatehouse and Park canal boat tours launch site; Moody Street Feeder Gatehouse (500 SF of Structural Composite Decking and 200 SF of Cast-in-place Concrete) that serves interpretation and educational programs at the gatehouse.

A fifth area, a track crossing, at Lowell High School (176 SF of Structural Composite decking and rubber track insert) that serves students and staff and general public use of the Ayotte Parking Garage, will be installed by Park

Facilities Maintenance staff.

The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Structural Composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing.

These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

The SOW includes replacement-in-kind of trolley platforms and sub-deck framing with structural composite for sustainability and long-term cyclic lifecycle. The Composite Decking and framing meet the intent of Preservation Brief 16 The Use of Substitute Materials on Historic Building Exteriors. Trolley track segments and ties will also be replaced-in-kind at the platform locations consisting of lifting track sections, removing ties and ballast down to grade, replacing ties, installing new ballast and re-installation of track sections. The proposed work will not

Project Leader: George Little

NEPA Specialist: David Lieb

NHPA Specialist: David Lieb

External Agency/Applicant:

Division/Office: Facilities

Designer:

Conceptual Design Date:

Project Type: Cyclic Maintenance

Project Category: Alternative Transportation Systems Cultural Landscape Deferred Maintenance Maintained Landscape

General Notes:

Locations

County/Borough, State District, Section Geo. Marker Other Tract ID

Middlesex, MA

File List

Title

313370 EXISTING CONDITIONS

PHOTOGRAPHS.pdf (1.7 MB, PDF file) Replace 4 Track Platforms 1 track Crossing and assoc ties graphic.pdf (15.5 MB, PDF file)

Last Updated Date: 02/04/2025

Last Updated By: glittle

Justification Form

Park Name: Lowell NHP

Project Number: 120536

Project Title: ATS-Rehabilitate Trolley System- Replace Five Track Platforms and One Track Crossing and Associated Ties

Public Safety: Yes

Energy Conservation:

Employee Health/Safety: Yes

Sustainable design: Yes

Partnership/Community Development:

Legal Mandate/Policy:

Citations/Violations/Court Orders:

Resources at Risk:

Other:

Brief Justification:

It is critical to the visitor experience and public safety to maintain trolley station platforms and associated track ties in compliance with code and accessibility standards and free from surface hazards. While the majority of track repairs are being carried out through 256838 - Repair Trolley Track Swamp to Wye and 256839- Repair Trolley Track Suffolk to Wye, those contracts avoid station platform areas because the station platforms need to be removed and replaced to access the track. The FIVE subject stations that are included in the proposed project:

Tremont Station (that serves the Suffolk Mill Turbine exhibit primarily for school groups); Mack Plaza Station (that serves the Park Visitor Center); Swamp Locks Station (serves Swamp Locks Gatehouse and Park canal boat tours launch site); Moody Street Feeder Gatehouse (serves interpretation and education programs at the gatehouse, reservation only). A fifth railway crossing, at Lowell High School (XX SF) that serves students and staff and general public use of the Ayotte Parking Garage, will be installed by Park Facilities Maintenance staff, but covered under this PEPC. The existing station platforms were installed approximately 15-20 years ago by Park staff and consist of pressure-treated joist sleepers with Trex composite decking. Due to age and deterioration, the decking surfaces at all stations and especially Mack Plaza Station (largest station area) are failing. Failures in surface decking are identified by structural deflection of the walking surface, creating tripping and safety hazards via upturned deck ends, and areas of sagging and heaving or upward bowing of areas as understructure has either settled or is failing. These failures also undermine the integrity and effectiveness of mechanical fasteners to keep surface conditions stable. All decks are well beyond life cycle and are in need of replacement.

Measurable Result:

Replacement of the existing track platforms and associated trolley ties will stabilize these four core trolley stations, mitigating deferred maintenance issues, potential track failures, annual repairs, emergency station closings for repairs, and position the stations to achieve a 25 year system performance. Once completed the project can be placed on a regulated annual internal inspection schedule, and planned replacement identified in FMSS for cyclic funding in the future. Stable, safe, non-hazardous and accessible trolley stations and platforms support visitor experience and connectedness of core historical and interpretation components of the interpretation and educational program offerings within the Park.