I write this as a member of the not- for- profit Board of Trustees of the Boys' Home in Covington, VA. I fully support the recommendations made by the Virginia Association of Independent Specialized Education  Facilites ( VAISEF). The specific recommendations with the outlined "Reasoning" made by VACIF have merit and should be adopted in full.

The regulations  as currently proposed would put inherent restrictions on the Board of Trustees and on the operation of the mission of the Boys' Home which has served this Commonwealth for the needs of young boys since 1905. Without the modifications  as proposed in writing by VAISEF, the program at Boys' Home may be compromised. With adjustments in the proposed regulations, all parties would be better served and the valid    intent of the Legislature would be upheld.

G.Chandler Williams , 2729 Kenmont Terrace, Midlothian, VA