Clinton Cemetery Conduct and Maintenance Rules for Ohio Veterans Memorial Park
Purpose and Scope
These Conduct and Maintenance Rules (the “Rules”) govern the conduct, stewardship, access, maintenance, and operational responsibilities associated with the Ohio Veterans Memorial Park (the “OVMP” or “Memorial Grounds”), located within and forming part of Clinton Cemetery property.
The Rules apply to the OVMP organization, its agents, contractors, volunteers, and to any person or organization granted stewardship permission or access for or to the Memorial Grounds, respectively, including but not limited to all invitees. They establish standards for care, appearance, safety, access control, security measures, structural alterations, and major feature installations, and define the limits of stewardship authority in relation to the Clinton Cemetery Association (the “Association”).
These Rules are adopted pursuant to the Association’s authority as owner and fiduciary of Clinton Cemetery under applicable provisions of the Ohio Revised Code and the 2007 Agreement to Erect a Permanent Memorial (the “2007 Agreement”). They are intended to supplement and operationalize the 2007 Agreement by clarifying expectations for ongoing maintenance, conduct, and oversight. They do not amend, supersede, or diminish the rights and obligations expressly set forth in the 2007 Agreement.
These Rules apply solely to the Memorial Grounds and to the conduct and stewardship activities occurring within that defined area. They do not establish maintenance standards for other areas of Clinton Cemetery, nor do they impose additional operational obligations upon the Association beyond those required under applicable law and the 2007 Agreement.
The OVMP organization is responsible for maintenance and upkeep of the 1.7-acre Memorial Grounds in accordance with the 2007 Agreement and these Rules, subject at all times to the Association’s oversight and continuing authority. The Memorial Grounds remain part of an active cemetery subject to ongoing burial operations and cemetery governance. For purposes of these Rules, the OVMP organization constitutes a Steward Organization as defined herein. Stewardship under these Rules is conditional, non-exclusive, and non-possessory.
Nothing in these Rules shall be construed to grant any ownership interest, possessory right, management authority over cemetery property, or exclusive stewardship entitlement. All activities on the Memorial Grounds remain subject to the Association’s approval where required under applicable cemetery rules and policies, including the separate Events Rules. The Association shall exercise its discretion in good faith and consistent with its fiduciary duties under applicable law.
Steward Duty and Limitations of Authority
Any organization permitted by the Association to steward, care for, or support memorial grounds, facilities, or activities on cemetery property (a “Steward Organization”) acts solely in a conditional and non-exclusive stewardship capacity. Such stewardship does not confer possession, control, management authority, or governing power over cemetery property, facilities, events, or persons.
A Steward Organization is responsible only for its own actions, representations, and omissions while present or acting on cemetery property. A Steward Organization shall not authorize, permit, encourage, legitimize, or represent that activities, events, construction, access restrictions, or other conduct are permitted on cemetery property except in accordance with the Association’s duly adopted rules and required approval processes.
Stewardship permission under these Rules does not limit, suspend, or transfer the Association’s continuous ownership authority over the Memorial Grounds. The Association may at any time, in the exercise of its fiduciary duties and rulemaking authority, directly perform, direct, or arrange for the performance of maintenance, management, security, or protective functions on the Memorial Grounds as necessary to preserve cemetery property, ensure public safety, and maintain compliance with applicable law and the 2007 Agreement.
A Steward Organization shall not represent to any third party, including contractors, volunteers, members of the public, insurers, or law enforcement, that it possesses authority to bind, control, exclude, supervise, or override the Association, its officers, directors, agents, invitees, or rules.
Upon becoming aware of unauthorized activity, a Steward Organization shall promptly refrain from legitimizing such activity, shall cooperate in good faith with the Association in addressing the matter, and shall take reasonable steps within its own conduct and communications to prevent recurrence. Nothing in this rule imposes strict liability upon a Steward Organization for unauthorized acts of third parties occurring without its knowledge or involvement.
Stewardship permission is granted on the understanding that a Steward Organization affirmatively undertakes the responsibilities associated with stewarding memorial grounds, including reasonable cooperation, coordination, and good-faith participation in the governance framework established by the Association. Stewardship is not a passive or nominal status.
A Steward Organization that declines, abandons, or persistently fails to perform its stewardship responsibilities, or that disclaims interest in carrying out such responsibilities while continuing to engage in activities on the Memorial Grounds, shall be deemed to have relinquished the basis upon which stewardship permission was granted.
Failure to comply with any provision of this section constitutes a breach of the conditions under which stewardship permission is granted. Because stewardship is conditional and non-exclusive, material noncompliance may result, at the Association’s sole and absolute discretion, in corrective direction, modification, suspension, or termination of stewardship permission, consistent with the Association’s governing documents and applicable law.
Access and Conduct
The Association and its authorized officers, directors, employees, agents, and representatives retain full, unconditional, and continuing rights of access to all portions of Clinton Cemetery property, including the Ohio Veterans Memorial Park grounds, facilities, structures, and improvements, for purposes including inspection, oversight, safety, compliance, maintenance coordination, rule enforcement, and fulfillment of the Association’s legal and fiduciary responsibilities.
No person or organization present on, using, or performing activities upon the Memorial grounds by permission, license, accommodation, or sufferance of the Association shall have authority to exclude, restrict, condition, or interfere with the Association’s access or oversight, or to represent to any third party that such authority exists.
Any interference with the Association’s access, oversight, or lawful presence on cemetery property, including obstruction, denial of entry, conditioning access on consent, or misrepresentation of authority to law enforcement, contractors, volunteers, or members of the public, constitutes a violation of these rules and of the conditions under which permission to be present or active on cemetery property is granted.
Any person or organization granted permission to place locks, regulate entry to, store materials in, or otherwise make use of any structure located on Clinton Cemetery property shall provide the Association with current keys, access codes, or other means of entry for such structures. The Association shall retain unrestricted, 24-hour access, without requirement of advance consent or approval, to all such structures for purposes including oversight, inspection, maintenance coordination, safety, compliance, rule enforcement and fulfillment of its legal and fiduciary responsibilities. Failure to provide or maintain current keys or access codes, or any action intended to limit or delay the Association’s access, constitutes a violation of these rules and of the conditions under which permission to use or maintain a presence within cemetery property is granted.
As required under the 2007 Agreement to Erect a Permanent Memorial, the OVMP organization is responsible for insuring the Memorial Grounds, including all improvements, buildings, and contents, against casualty and loss, and for maintaining liability insurance covering both parties to the Agreement. For purposes of stewardship oversight and risk management, liability insurance shall carry coverage of not less than two million dollars ($2,000,000) and shall name the Clinton Cemetery Association as an additional insured. Certificates of insurance for both policies shall be provided to the Association annually, or upon renewal. The Association shall be provided thirty (30) days’ prior written notice of any cancellation or material modification of coverage.
For any event or activity conducted on the Memorial Grounds with the required approvals, the steward organization shall be responsible for and accountable for all event-related logistics, including staffing, setup, teardown, opening and closing, cleaning, security coordination, and restoration of the grounds and facilities. The steward organization’s responsibilities under this rule are independent of any third-party participation and do not transfer to event sponsors, vendors, or invitees.
No steward organization, officer, director, volunteer, agent, or representative operating on Memorial Grounds may grant, imply, or represent that permission exists for any activity, gathering, or event to occur on Memorial Grounds outside of the established event approval process. This prohibition includes informal assurances, verbal approvals, “go-ahead” communications, coordination with third parties prior to approval, or any conduct intended to bypass or undermine the formal events policy. No representation, assurance, or informal authorization by a Steward Organization or its representatives shall be construed as valid event approval or as binding upon the Association. Only approval issued through the Association’s established event approval process constitutes authorization.
Security & Surveillance
Responsibility for security measures on portions of cemetery property used by a Steward Organization may arise from written agreements with the Association, including the 2007 Agreement. Any such responsibility relates solely to outcomes such as theft prevention and vandalism deterrence and does not confer governance authority or the right to control, restrict, supervise, monitor, or regulate persons or activities on cemetery property, except as expressly authorized in writing by the Association.
Consistent with the limitations set forth in Rule 1, any video surveillance equipment installed in structures or areas of cemetery property used by a Steward Organization must be clearly visible and conspicuously marked and may be used solely for general security purposes.
No surveillance or security measure shall be installed without prior written approval of the Association.
No equipment shall be installed, utilized, or enabled on cemetery property for the purpose of recording, transmitting, or monitoring audio or oral communications, or for the purpose of conducting biometric identification, facial recognition, behavioral analysis, or similar identification or tracking of individuals, except as expressly permitted and required by law.
Security or surveillance measures shall not be installed or used for the purpose of monitoring meetings, conversations, or activities of the Association or its representatives, nor shall such measures be used in a manner inconsistent with Rule 1 of this section, including any attempt to restrict, supervise, regulate, or influence the Association’s lawful access, oversight, or governance activities.
The Association retains the right, at its discretion, to inspect, review, and require modification, reconfiguration, or removal of any surveillance or security equipment or systems installed on cemetery property if such equipment or systems are inconsistent with these Rules, the 2007 Agreement, applicable law, or the purposes and dignity of the cemetery. All surveillance and security systems remain subject to the Association’s continuing oversight authority.
Misrepresentation of surveillance authority or use of security measures to restrict, exclude, influence, or interfere with lawful Association access, oversight, or governance functions constitutes a violation of these Rules and of the conditions under which permission to use cemetery property is granted.
Any video, metadata, logs, recordings, or other information generated by surveillance, monitoring, or security systems operating on cemetery property constitutes information subject to the Association’s oversight authority. Upon request, the Association shall be provided prompt and unrestricted access to such information, including live access where available and copies of stored data in a commonly readable format.
No person or organization operating surveillance or monitoring equipment on cemetery property may withhold, materially restrict, unreasonably delay, alter, delete, or condition the Association’s access to such information.
Surveillance data relating to incidents, disputes, safety matters, rule enforcement, interactions with law enforcement, or potential claims shall be preserved upon written request by the Association. Absent such a request, data may be maintained and deleted in accordance with a documented retention policy approved by the Association. Once a preservation request is made, such data shall not be altered or destroyed except as authorized in writing by the Association.
Any surveillance or monitoring systems installed on cemetery property that utilize third-party cloud storage or vendor-managed platforms shall be configured to ensure that the Association possesses independent administrative access credentials sufficient to exercise its rights under these Rules. Vendor agreements or platform terms shall not limit, condition, or impede the Association’s access to surveillance data or system controls as provided herein.
All security-related conduct, technologies, and data practices on cemetery property remain subject to these Rules and to the Association’s oversight authority. These provisions are intended to ensure transparency, prevent the expansion of governance authority through technological means, and maintain compliance with applicable Ohio laws governing recording, privacy, and property rights.
General Maintenance Responsibilities
All areas of the memorial grounds shall be maintained in a neat, clean, and safe condition at all times.
No structural change or permanent alteration to monuments, buildings, or the designed landscape layout shall be made without prior written authorization from the Association, which may be granted or withheld in the Association’s sole and absolute discretion. Routine landscaping, pruning, or seasonal plant replacement does not require prior approval.
Maintenance activities shall be performed with due care to avoid damage to monuments, pavers, plantings, or infrastructure.
Any hazardous condition or damage observed shall be reported promptly to the Association, and the OVMP organization shall take appropriate action to address the issue in accordance with its responsibilities under the 2007 Agreement and the Rules.
Restoration of damaged improvements shall comply with the installation and alteration standards set forth in these Rules.
Walkways and Paved Surfaces
Walkways, brick paths, and concrete surfaces shall be kept clean, free of stains, soil, residue, or algae.
Walkway edges and joints shall be maintained free of grass, weeds, and organic growth.
Paver joints shall be filled and stabilized to prevent gaps or displacement.
Engraved pavers shall remain legible and uniformly clean. Any faded or damaged unit shall be repaired or replaced.
Stamped concrete or transition areas shall be free of cracks, erosion, or buildup.
Snow and ice shall be removed promptly from all walkways and paths when conditions warrant.
Monuments and Granite Features
All granite panels, monuments, and bases shall be kept free from film, stains, and biological residue.
Gilded, engraved, painted, and polished elements shall be maintained to ensure legibility and appearance.
Memorial items or tributes placed at the base of monuments shall be inspected periodically and removed or restored when weathered or deteriorated.
No major monument or plaque shall be structurally altered, relocated, or cleaned using nonstandard materials without prior written authorization from the Cemetery Association, which may be granted or withheld in the Association’s sole and absolute discretion. Routine cleaning with customary methods is permitted without prior approval.
Landscaping and Vegetation
Planting beds and turf areas shall be maintained free from weeds, invasive grass, and overgrowth.
Mulch and decorative stone shall be level, replenished, and free from soil or weed intrusion.
Turf shall be kept evenly trimmed, irrigated, and reseeded where necessary.
Plants and shrubs shall be pruned, trimmed, or replaced when overgrown, faded, or dead.
Soil erosion or sediment buildup near walkways, beds, or structures shall be corrected promptly.
Flags and Ceremonial Items
Flags shall be displayed respectfully, kept clean and wrinkle-free, and replaced when faded, frayed, or weathered.
Flagpoles, halyards, and mounts shall remain upright, structurally sound, and corrosion-free.
Flag displays shall comply with the United States Flag Code and be illuminated during nighttime display.
Structures and Fixtures
Benches, railings, gazebos, and other ancillary fixtures shall be cleaned regularly.
Painted or metal fixtures, including donation boxes and trash receptacles, shall be kept rust-free and repainted as needed.
Display vehicles, artillery, and large artifacts shall be maintained clean, rust-free, and properly painted to preserve historical character.
Benches, engraved bricks or pavers, photo-engraved plaques, and other donor-sponsored memorial elements installed within the Memorial Grounds shall conform to the established design standards, including standards relating to style, materials, dimensions, finish, and placement. The Steward Organization shall ensure that donor-sponsored elements are procured and installed in a manner that maintains visual consistency and coherence with existing memorial elements and the overall design intent of the memorial. This requirement applies to all donor-sponsored memorial elements, whether existing categories or new types introduced in the future.
Any change to the established design standard for a category of donor-sponsored memorial elements, including changes to style, form, materials, size, or finish, or the introduction of any new category of donor-sponsored memorial element shall require prior written authorization from the Association before new items of that type are offered for purchase or installed.
Photo-engraved memorial displays shall be kept clean, intact, and free of deterioration. Displays that remain incomplete until additional panels or images are added shall be kept in a visually finished condition, free of exposed backing, raw edges, or other features that create the appearance of an unfinished or under-construction display.
Fire pits, benches, and related plaza furnishings shall be cleaned after each use and kept free from ash or residue.
All event furnishings, folding tables, or temporary structures shall be inspected after each use and stored neatly when not in use.
Building Systems, Utilities, and Equipment
HVAC systems, electrical components, and plumbing fixtures shall be maintained in proper working order by qualified personnel.
Exterior mechanical units shall be kept clear of vegetation.
Exterior equipment, such as pumps or lighting fixtures, shall be kept clean, secure, and functional.
The septic system serving Heroes Hall shall be inspected annually and pumped as needed to ensure sanitary function.
All building systems shall comply with applicable safety standards and codes.
Service Areas, Driveways, and Parking Areas
Driveways, parking areas, and perimeter edges shall be kept clear of debris, soil buildup, and erosion.
Concrete pads and service areas shall remain level, stable, and visually maintained.
Trash receptacles shall be emptied before full and kept sanitary and odor-free.
Driveways and parking areas shall be maintained free from potholes, washouts, and obstructions.
Surfaces shall be swept or cleaned regularly to remove debris and gravel.
Drainage features shall be inspected seasonally to prevent water accumulation and erosion.
Snow and ice shall be removed promptly from all vehicular and pedestrian access areas when conditions warrant.
Parking lot striping and directional markings shall be maintained in clear, legible condition.
Overnight parking or storage of vehicles within the memorial area is prohibited except upon prior written authorization of the Association, granted or withheld in its sole and absolute discretion.
Water Features
Reflecting ponds, streams, and fountains shall be cleaned to prevent algae, weeds, sediment, or floating debris.
Water clarity and circulation shall be maintained through proper maintenance of pumps and filters.
Vegetation around water features shall be trimmed and maintained to preserve visibility and prevent obstruction.
Surfaces adjacent to water features shall be kept clean and free from stains or organic buildup.
Heroes Hall (Interior Cleaning & Upkeep)
Heroes Hall shall be kept in a clean, orderly, and presentable condition at all times, reflecting the solemn purpose of the memorial.
Floors shall be mopped or vacuumed and surfaces dusted, regularly.
Windows, glass doors, and fixtures shall remain free of smudges and fingerprints.
Restrooms shall be regularly cleaned, sanitized, and stocked with necessary supplies.
Trash shall be removed promptly after each use or event.
Heroes Hall shall be inspected before and after every scheduled event to ensure it is clean and restored to standard condition.
Event-related decorations or displays shall be temporary and removed immediately following each event.
Inspections and Reporting
The OVMP organization shall maintain a written maintenance log documenting inspections, cleaning, and repairs.
The Association may conduct inspections at reasonable intervals and require corrective action for any condition not meeting these standards.
Any unsafe or deteriorated condition must be reported immediately to the Association, along with a description of the steps taken or scheduled to address the issue.
Major Feature Installation
Professional Design, Execution, and Visual Integrity
Any proposed installation of a major memorial feature, including but not limited to aircraft, vehicles, or other large artifacts, shall require prior written authorization from the Clinton Cemetery Association. Inclusion of a feature within the 2007 Agreement drawings shall not constitute authorization for installation absent compliance with the requirements of this section.
Authorization shall be based upon submission of a written installation plan prepared and executed by a single qualified outdoor design-build firm, or by a coordinated team of licensed professionals operating under a designated lead firm, with demonstrated experience in the design and construction of outdoor memorials, parks, or comparable public installations.
The installation plan shall identify the firm or firms responsible for design and execution and shall represent that the proposed installation complies with the 2007 Agreement to Erect a Permanent Memorial, applicable resolutions of the Cemetery Association, all applicable laws and codes, and insurance requirements. Where required by law, code, or insurer, the plan shall include drawings stamped by a licensed architect or professional engineer authorized to practice in the State of Ohio.
The submitting firm shall be responsible for determining the professional, technical, and regulatory requirements applicable to the installation and for ensuring that the design and construction satisfy those requirements.
The installation plan shall also demonstrate that the proposed feature is professionally designed, durable, and visually appropriate for a permanent memorial situated within an operating cemetery, and that it is consistent in scale, character, materials, and finish with the established design intent of the Memorial Grounds.
The Association may withhold authorization if the proposed installation, while technically compliant with minimum requirements, fails to reflect a level of professional quality, durability, and aesthetic integration appropriate to a permanent memorial of this character and location.
In evaluating installation plans, the Association shall exercise its review in good faith and in furtherance of its fiduciary obligation to preserve the integrity, dignity, and long-term character of cemetery property.
The Clinton Cemetery Association’s authorization shall constitute approval to proceed based on the qualifications of the submitting firm and the representations made in the installation plan and shall not be deemed a technical review or validation of the design or construction methods and, as such, the Association shall have no responsibility for the architectural soundness, compliance with laws or building codes or any other construction requirements for the materials or techniques set forth in the plans.
The installation shall be constructed in substantial conformity with the approved installation plan, including mounting method, elevation, orientation, and anchoring specifications. Any material deviation shall require additional written authorization from the Association.
The Ohio Veterans Memorial Park organization shall not act as a general contractor or undertake self-performed installation of major memorial features unless expressly authorized in writing by the Association.
Temporary Placement of Major Features Pending Installation
This rule applies to major memorial features subject to the installation requirements set forth above.
The temporary placement of a major memorial feature or artifact on the Ohio Veterans Memorial Park grounds, prior to approved installation, shall not be deemed approval of the feature’s installation, location, mounting method, or compliance with any applicable resolution, rule, or provision of the 2007 Agreement.
Any such temporary placement shall be considered provisional only and shall not satisfy or substitute for the installation requirements established by the Cemetery Association, including those governing mounting, elevation, orientation, or design intent.
Temporary placement may be permitted for a limited duration while an approved installation plan is being prepared or finalized. Placement that remains without demonstrable and continuous progress toward submission and approval of an installation plan may constitute noncompliance with applicable resolutions or rules governing the feature.
The Association reserves the right to require removal or relocation of any temporarily placed feature that remains on memorial grounds without approved installation or active construction toward compliance.
Compliance with any feature-specific resolution or display rule shall not eliminate the requirements of this section unless expressly stated.
Enforcement
Failure to comply with these rules may result in written notice from the Association requiring corrective action. Continued noncompliance may lead to suspension of privileges or other remedies permitted under the 2007 Agreement and Ohio law. Notwithstanding the foregoing, the failure of the Association to strictly enforce any of these Rules at any time shall not constitute a waiver of the particular rule at issue or the Rules in whole or in part.
These rules were adopted pursuant to Article Seven, Section 7.6 of the Amended Code of Regulations on 3/12/2026. The official adopted version is maintained in the records of the Clinton Cemetery Association. In the event of discrepancy, the officially adopted version controls.