Blair H. Nelsen CFUE, CCRE, CFSP

Director, Eastern Region -- 416 West Franklin Street -- Richmond, Virginia  23220

November 6,2015

Cemetery Board

Department of Professional and Occupational Regulation

9960 Mayland Drive, Suite 400

Richmond VA 23233-1485

RE:      Revisions to 18 VAC 47-20-180, 18 VAC 47-20-190, 18 VAC 47-20-270,

and 18 VAC 47-20-280

via electronic delivery

Dear Sir or Madam:

I write to you on behalf of Service Corporation International (“SCI”) and its affiliates doing business in the State of Virginia.  Please accept this letter as SCI’s submission of its comments related to the Cemetery Board’s proposed revisions to 18 VAC 47-20-180, 18 VAC 47-20-190, 18 VAC 47-20-270, and 18 VAC 47-20-280.  Thank you for taking the time to review my letter.

SCI is in agreement with the proposed changes to 18 VAC 47-20-180, 18 VAC 47-20-270, and 18 VAC 47-20-280.  In regards to the proposed changes in section 18 VAC 47-20-190 and 18 VAC 47-20-190, I believe that the language in sub-sections 16 and 17 may create a burden for cemeteries.  Therefore, I suggest some amendments which I believe will have the same intended effect of ensuring that the public is aware of the existence of a pet/human section within a cemetery.

Below are the suggested amendments to the proposed revisions:

Option 1 -- STRIKE Item 16 & Amend Item 17 to read: "Failing to clearly mark or advertise the section(s) devoted to the interment of pets or the interment of human remains and the pets of such deceased humans with signage that is reasonably apparent to the general public."

Option 2 -- AMEND Item 16 to read:  "If a cemetery company has a section devoted to the interment of pets or the interment of human remains and the pets of such deceased humans, any advertisements failing to clearly state the cemetery company has such section(s) in its cemetery. and the GPL fails to clearly state the cemetery company has such section(s) in its cemetery."

SCI hopes that the Board will consider the above suggested amendments.  Please feel free to contact me if you would like to discuss further.

Very truly yours,

Blair H. Nelsen CFUE, CCRE, CFSP