Representation is less in the author's meaning and more in the reader's interpretation, because the reader is the one recieving a message, not the author. No matter what an author MEANT by something, or if he or she meant anything, doesn't really matter, it's how it is interpreted that is important. That is, unless the author comes out and says, "I meant such and such." As long as somebody can reasonably back up why they think something is a representation of something else, he or she has pretty much done all a person can do to show the a representation short of asking the author.
Which means that, despite what Tolkien wanted the allegory to be, or if he wanted one at all, the Lord of the Rings is pretty much an allegory of industrialization.
And e, I know you aren't arguing this point, but I don't think that saying the Lord of the Rings is an allegory for WWII is a very good argument at all, and I don't think that saying that elvish was based on finnish is a good argument, either. I mean, a language doesn't signify a political alignment, if elvish had been based on Japanese would that have made the elves an allegory for the Japanese? I doubt it. I think it is much more likely to be because Tolkien knew Finnish and didn't want to base Elvish on english, or perhaps he just really liked Finnish.
A better argument would be that although the Germans did industrialize tremendously previously to and into WWII thanks to Bismark, so did Britain and America, so saying that the orcs are germans because they industrialized is a very, very bad argument.