22 June 2007

Mr. Stephen Morris

Chief, Office of International Affairs

National Park Service

Department of the Interior

Washington, D.C. 20240

Dear Mr. Morris,

As you requested in your letter of May 29, 2007, we are responding to
your comments on the Poplar Forest application for the U.S. World
Heritage Tentative List.

Your letter and subsequent conversations with you and your staff
identified the primary issue as "that of the historic integrity and
authenticity of Poplar Forest relative to the State Capitol and the two
other Jefferson properties already included in the World Heritage List."
It has not been possible at this stage to reply jointly with the State
Capitol but we have been in contact with the staff of the Department of
Historic Resources and will jointly prepare any additional information
that might be required in the future.

The best way to respond to the authenticity and integrity question is to
refer to the [Operational Guidelines of the World Heritage
(OP)]{.underline}. At Poplar Forest the principal significant attributes
have been identified as the original octagonal house, the two original
octagonal privies, the service wing, and the landscape setting, both
natural and manmade. The OP states that the basis for assessing all
aspects of an attribute's authenticity is the knowledge and
understanding, based on credible and truthful sources, of the nature,
details, meaning and history of the cultural heritage (par. 80, 84).
Further, each attribute should be assessed on its design, materials,
workmanship, and setting (par. 81). Extensive descriptive information is
contained in the original nomination of Poplar Forest regarding all of
these points. It is the intention of this response to clarify these
aspects of authenticity and integrity by grouping them in summary form
without repeating or rewriting the nomination at this time.

### Authenticity

Regarding information sources as defined by the NARA Document, the
authenticity of information for Poplar Forest is extremely high. This
information consists primarily of physical evidence in the standing
structures and existing landscape, archaeological evidence in the
ground, and in prototypical evidence of similar features designed by
Jefferson and constructed by the same craftsmen that still exist at
Monticello and the University of Virginia. The other significant source
of information is the remarkable two-way explicit correspondence through
letters between Jefferson and the workers building Poplar Forest. The
scope, range, quality, and detail of this correspondence is unique in
architectural history, the only exception being Monticello. It is
perhaps more unique than Monticello because at Poplar Forest Jefferson
corresponded directly with hired and enslaved workers as opposed to
family or overseers at Monticello. This correspondence covers the entire
period of the construction, 1805-1826. The documentary record is best
conveyed through S. Allen Chambers, Jr.'s definitive history, [Poplar
Forest and Thomas Jefferson]{.underline} (1993).

# Design, Materials and Workmanship

## Figurative Information

Jefferson's initial drawings for house and outbuildings, and some by one
of his workers, provide the figurative design history of how Jefferson
arrived at the full-blown octagon shape for Poplar Forest, America's
first true octagonal house. Extensive photographs from ca. 1900 -- 1970
document how the house evolved for different owners and lifestyles. The
last family's changes to the house in the 1945-1979 period are
documented in architectural drawings and specifications.

## Written Information

Jefferson's use of the ploygraph machine, which made two identical
letters at the same time, enabled him to keep copies of the letters he
sent regarding design, construction, materials, and many other aspects
of Poplar Forest. Jefferson habitually kept all return letters, creating
a full correspondence history. In addition, Jefferson's numerous daily
journals kept track of every expenditure and provide a unique American
analytical record of construction and its technology. For the post
Jefferson period correspondence of Jefferson's grandson describe that
occupancy. The later Cobbs/Hutter family kept daily farm journals,
photographs and family letters, documenting the period 1828-1945.

## Physical Information

The physical documentation of the original buildings is contained in the
extensive investigation and restoration records in the Poplar Forest
archives. The investigative phase of the project has won awards for its
careful and thorough process and is considered a professional model.
Both interior and exterior examination confirmed many of the features
and trim documented in correspondence. Certain nuances of a particular
worker's craft could be determined from his work at Jefferson projects
before and after Poplar Forest since Jefferson documented which worker
was responsible for which parts on his different projects and typically
workers were employed for many years. The 1814 wing of service rooms was
the most altered with two out of the four rooms removed in the 1840s.
Archaeology confirmed all the plan features of the wing while a detailed
letter described the Jeffersonian roof system, leaving little
conjecture.

# Location and Setting

The same types of information are available for understanding the
natural and designed landscape. Jefferson's correspondence and his
journals document his evolving designs within the five-acre ornamental
core and in the outer yards. Later families document changes through
their own correspondence and journals. Maps, plats and photographs from
Jefferson's period onward document the site in figurative ways.
Physically, the features that were sculpted or planted by Jefferson are
either still existing or have been confirmed through archaeological
excavations which have been ongoing since 1988. Landscape archaeology
has confirmed much of the rich documentary record of Jefferson's
ornamental plantings, species of trees and shrubs, fields, roads,
fences, outbuildings, and yards. The ornamental core still contains the
ancient poplar forest on the north and the symmetrical mounds acting as
Palladian pavilions to the house. The sunken lawn on the south frames
the man-made side of the core. The landscape at Poplar Forest has been
described as "one of the best documented gardens in early America."

# Integrity

The Operating Guidelines define integrity as the wholeness of the
natural or cultural heritage that must be measured in values related to
its elements, size, and encroachments (par. 88, 89). The significant
attributes of Poplar Forest regarding its universal values are intact.

# Design, Materials and Workmanship

The most important characteristic feature of the site is the main house
with its solid brick walls forming its Jeffersonian octagonal shape.
This survived through time without additions and retained its original
shape with porticos, columns and stair pavilions. Jefferson himself
added the east wing to the house in 1814 but never built the west wing.
One half of the wing was removed in the 1840s. The two octagonal privies
survived very intact with a high degree of original fabric and features.

In the past fifteen years the Jefferson buildings have been undergoing
conservation and restoration. As documented in the nomination, the
idealistic nature of this process has garnered praise from all
professionals who have visited the site. The integrity of the process,
and its results, could not be higher. The Getty Institute, which is
known for only funding "conservation" and not "restoration," funded a
multi-year project for the conservation of original materials at Poplar
Forest that totaled nearly one million dollars. In terms of restoration,
architectural trim and modern systems added to the house in the 1840s
and 1940s were removed and appropriate Jefferson era details and
materials restored. Due to the extensive documentary and physical
evidence described in the section above, there was very little
conjecture in restoring the Jeffersonian features. The traditional
materials and techniques of construction have given the project a great
intangible heritage value as modern visitors have witnessed early
nineteenth-century processes. The actual historical sequence of
finishing the house as Jefferson did over a fourteen-year period is
unique among museum restoration projects, showing the finished or
unfinished state as Jefferson would have lived in the on-going project.
Authentic materials have been used regardless of cost and difficulty in
obtaining them. There are no deadlines in doing the restoration work
other than doing it correctly. The integrity of this professional
process is without question.

The features needing the greatest spatial restoration were the upper
walls of the central cube room, having been reduced from twenty feet to
twelve feet, and the western portion of the service wing. To quantify
this work, roughly twenty thousand custom reproduction bricks were
necessary for this work out of a total of 250,000 bricks used in the
buildings. Poplar Forest also pioneered the return to a traditionally
made lime putty for use in mortar, plaster and render.

# Location and Setting

The ornamental five-acre core, designated as the official nomination
boundary selection, retains its original features to a great degree.
Jefferson's "structural" landscape is still defined by the ring road
enclosing the trees of the natural forest on the north, the carriage
turn-around space leading to the house, the symmetrical mounds flanking
the house, and the sunken lawn on the south. These surviving core
features allowed landscape architect C. Allan Brown to interpret
Jefferson's mathematical composition of European-inspired garden
features in combination with the natural world concluding: "the
integrity of concept at Poplar Forest remains clear and in contrast to
the idiosyncratic character of Monticello...."

In terms of the "adequate size for representation of features," the
outer ten-acre square yard is intact and the sixty-one acre curtilage
yard is mostly intact. The more than 600 acres of property acquired by
the corporation at great cost of the past twenty-five years was the
heart of the principal 1,000-acre plantation on Jefferson's original
5,000 acres. This land is still in the same character of woods and
fields, conveying the feeling of the agricultural landscape through
which the visitors travel to get to the ornamental core of the villa
retreat. The more transient landscape features not present, such as
ornamental trees, flowers and shrubs, are well documented, confirmed by
archaeology, and might be authentically restored in the future.

The most serious encroachment of development in relationship to the core
and the broader corporation boundaries is that south of the core. In
this area residential houses have been built within the southern portion
of the 61-acre curtilage yard. The corporation is determined to acquire
ownership of about 20 houses in this area and to eventually return the
land to its original character. About one-third of this area has been
acquired in the past ten years. A significant recent purchase of 100
acres has kept commercial development further away from the historic
heart of the property. Land acquisition for purposes of protection has
always been the highest priority.

# Comparative Analysis 

The NPS response to the Poplar Forest nomination stated: "Any extension
would also need to include comparative information in a wider context
than the three other extant works by Jefferson." In our preparation for
writing the nomination we were guided by "The Guide to the U.S. World
Heritage Program," section 3.c., which states: "Preparing a comparative
analysis will be relatively easy if similar sites are already inscribed
in the World Heritage List. In that case, it is only necessary to
determine what features either distinguish the site proposed from those
properties and allow it to be regarded as more, equally, or jointly
worthy." This comparison was accomplished in our nomination is Sections
3.b.,c.,and d. Poplar Forest meets or exceeds the authenticity and
integrity sited for Monticello and the University of Virginia, and along
with the Virginia Capitol, is jointly worthy of the inscription.

The integrity issue is equated by some as a degree of physical change
and to the extent features of a building or site have been restored. It
is clear that this standard has not been consistently applied to many
inscriptions on the World Heritage List, either in the United States or
worldwide. It is an issue that is hard to quantify, as acknowledged in
the OP (par. 81): "Judgments about value attributed to cultural
heritage, as well as the credibility of related information sources, may
differ from culture to culture, and even within the same culture. The
respect due to all cultures requires that cultural heritage must be
considered and judged primarily within the cultural contexts to which it
belongs."

This guideline acknowledges that integrity must be judged in the proper
context. Regarding a type of building as a form of heritage, the OP
further states (par. 89): "Relationships and dynamic functions present
in cultural landscapes...essential to their distinctive character should
also be maintained." If we are to comparatively judge the four Jefferson
sites using their dynamic functions and character, they should be seen
in two categories: public institutions, represented by the University of
Virginia and the Virginia State Capitol; and private domestic
residences, represented by Monticello and Poplar Forest. The eternal
power and value of the University of Virginia is the fact that its
character and tradition as a university has not changed; its "dynamic
function" continuously reinforces Jefferson's symbolic forms related to
their associated universal ideas. As a continuously used public
institution that is nearly two hundred years old, especially a
university that must remain modern, it has undergone physical change,
additions, and restoration. Yet it retains its world heritage values.
The same can be said for the Virginia State Capitol. Its power and value
is not only its original symbolic political and architectural
significance, but the fact that it has continuously been used for the
same purpose, retaining its original character that is enhanced by its
"dynamic function." That changes and additions have been necessary for
it to meet modern needs is to be expected.

Similarly, the domestic character of Monticello and Poplar Forest
reflect the fact that families continued to live in these houses into
the twentieth century. In the context of American houses, and even of
many outside of America, there are very few examples where modern living
did not affect physical changes that can be reversed in restoration if
it is important to do so. If we were to consider buildings on the World
Heritage List, most would have been altered over time unless they were
arrested in their original state as a ruin. What is the relative value
of a ruin with integrity versus the dynamic value of buildings that have
continued to function and to inspire as originally intended? The
important factor to consider in restoration is the authenticity of
knowledge and the integrity of the work. Part of that integrity is the
intangible heritage of feelings and spirit the site can still elicit
(Poplar Forest nomination Section 3).

**The Extension of a Thomas Jefferson Listing**

We understand that in determining a Tentative List your Committee wishes
to give priority to sites that are not already on the World Heritage
List. This is understandable. On the other hand, Thomas Jefferson's
ideas and works are of Universal Value. The current listing is
incomplete without the State Capitol and Poplar Forest as they are not
redundant examples of his work and they are both necessary to fully
understand and appreciate any and all of his work and its value. Why do
we need an extension of the Jefferson listing? The answer is found in
the word "heritage." David Lowenthal, the foremost thinker and definer
of cultural heritage, insists that "Heritage is not history at all;
while it borrows from and enlivens historical study, heritage is not an
inquiry into the past but a celebration of it, not an effort to know
what actually happened but a profession of faith in a past tailored to
present-day purposes." Cultural Heritage then, can be defined as the
parts of the past that continue to be relevant to our present and
future. A few statistics used in the Poplar Forest nomination
demonstrate very simply whether Thomas Jefferson and his work is history
or heritage, whether his legacy is relevant or redundant: In the years
1996-2005 the OCLC database at the Library of Congress recorded that the
subject heading "Thomas Jefferson" was reflected in 716 books, 300
audio-visual works, 200 academic dissertations or theses, and in the
year 2005 alone, there were 1,100 newspaper or periodical articles on
Thomas Jefferson. What other figure in world history and world heritage
can claim that relevancy? The Thomas Jefferson listing on the World
Heritage needs to be extended in order to make whole its own integrity.

We would be happy to provide any additional information on any questions
regarding our application.

Sincerely,

Travis C. McDonald

Director of Architectural Restoration

Thomas Jefferson's Poplar Forest

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April Brooks, 6-22-07