Perhaps it would be wise to look at the FAA website to see what the FAA considers commercial use where you should comply with Part 107:
https://www.faa.gov/uas/getting_sta...ons_terms_Special_Rule_for_Model_Aircraft.pdf
“Commercial use:
Flying your drone with the intent of generating monetary profit for your business, or to promote your services as a professional drone operator.
This includes sharing promotional drone footage or photos via digital channels for free.”
That could be where the hangup is. I am not in the business and don't intend to generate income. I am not promoting my services. I don't know whether the cemetery association actually even sells plots in the cemetery. I think it relies on donations from church members to fund it.
I looked up the definition of "promotional". " Relating to the publicizing of a product, organization, or venture so as to increase sales or public awareness."
I don't think they are trying to increase sales, since it is a private cemetery. (I think) Maybe the public awareness part would though. Thanks