Oct 31 , 2015 Family Memories Photography 13005 Point Richmond Drive NW Gig Harbor, WA 98332
U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE. Washington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM
Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), Family Memo ries Photography , the operator, and Sue Burnett owner and pilot Roy Burnett seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial System to allow for commercial operations of one DJI “Inspi re 1” four rotor UAS’s (Inspire 1), one DJI Phantom 2 four rotor UAS’s with an attached DJI H3

- 3D Gimbal Mount holding a GoPro Hero 3+ with attached 3 axis gimbal mount for the purpose of aerial photography and video for a variety of industries.
**THE UNMANNED AIRCRAFT (UA):**  The Inspire 1 has a maximum takeoff weight of approximately 7.6 pounds. It has a diagonal length of 451mm and a maximum speed of 22 meters per second. DJI Phantom 2 has a maximum takeoff weight of approximately 2.9 pounds. It has a diagonal length of 350mm and a maximum speed of 15 meters per second. Inspire 1 and the Phantom 2 both Manufactured by DJI include th e following equipment in flight: 1. An on

-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground

-based transmitter/controller. 2. An on

-board camera capable of capturing imagery in the form of full color, high de finition still photos and video. 3. An on

-board telemetry system using GPS flight that delivers flight data from the on

board flight computer to the on

-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site. 4. A 5GHz and 2.4GHz for the Inspire 1 and 2.4GHz for the Phantom 2s on -board radio transmitter that transmits live HD video from the on

-board camera plus all the flight data from the t elemetry system described above.**THE GROUD STATION**
**- BASED**  **EQUIPMENT AND CREW :** 

1. A Pilot in Command ( PIC) in operational control of flight operation from b eginning to end who c ontrols the UA while in the air. 2. A 2.4GHz radio transmitter/controller operated by the PIC to control the UA Phantom 2 while in flight. A 5GHz and 2.4GHz radio transmitter/controller is used for the Inspire 1

. 3. A radio receiver receiving live video and flight data from the on

-board camera and computer, proje cting it all together onto a screen fo r the PIC to view during flight. 4. A V isual Observer (VO) provides a second pair of eyes to visually track the UA while in flight. 

## Summary The requested exemption would support an application for a commercial Certificate of Authorization for Family Memories Photography to provide aerial photography and other photography services for real estate agents, real property appraisers, property managers, general contractors ; utilities and industries (only whe re safe flight is attainable), Chambers of C ommerce , community events , weddings, marine properties , resorts , wildlife conservation organizations, public departme nts, all other institution requiring filmography (safe flight permitting) and never operating over persons not dire ctly involved

. The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. It operates at lower altitudes with no people on board, thereby reducing current risk levels and enhancing safety and diminish ing the likelihood of death or serious bodily injury. With a small payload and maximum flight time of o nly 18 minutes, there is little or no risk to national security. Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The altern ative could be to charter a full

- sized helicopter for this purpose, which has proven more costly than many potential clients are able to afford. This benefit s many buyers and sellers of real property and marine property

. Additionally, we request that we b e allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. The Family Memories Ph otography UA s will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: a) No flight will be made with a UA with gross weight exceedin g 55 pounds. b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at airspeed of no more than 50 knots and no f urther than 3/4 NM from the PIC. c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation. d) Operations will be restricted to flights over property with the p ermission of the property owner. e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51. f) A ll required permits will be obtained from state and loca l government prior to operation. g) The Family Memories Photography will not be operat ed over densely populated areas.h) The Family Memories Photography wi ll not be operated at air shows.

i) The Fami ly Memories Photography will not be operated over any open - air assembly of people. j) The Family Memories Photography will not be operate d over heavily trafficked roads. k) The Family Memories Photography will not be operated within 5 NM of an airport or h eliport. l) Operations will be restricted to day only and weath er conditions equivalent to VFR. m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location. n) No flight may be made without a Pre

- Flight Inspection by the PIC before each operation to ascertain that the UA s are in a condition safe for flight

. The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training. We submit that the combination of the UA's light weight, flight performance and ability, qualified flight crew and strict o peration proc edures under the guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation we undertake will have an equivalent or greater level of safety than manne d aircraft performing the same mission. The name and contact information of the applicant is : Family Memories Photography: Roy Burnett Ph one : 253

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- 1013 Email: roynsueb@comcast.net Exemptions/Rule Making Regulations from which the exemption is requested : 14 CFR Part 21 14 CFR 45.23(b) 14 CFR 45.29 14 CFR 61.23 14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409( a)(2) 14 CFR 417(a) & (b) 14 CFR Subpart E (91.401

- 91.417)
AUTHORITY FOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulationprescribed under subsection (a) or (b) of this sectio n or any sections §44702

- 44716 of this title if

the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). Section 333(b) of the Reform Act assists the Secretary in determining whether UASs may operate in the national airspace system without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:
1. The UASs size, weight, speed and operational capability; 2. Whether the UAS operates within the visual line of sight of the operator; 3. Whether the UAS operates outside of highly populated areas and away from close proximity to airports. Reform Act 333 (a). If the Secretary determines that a UAS "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id . 333 (c). The DJI Inspire 1 is a m

ulti

- rotor aircraft weighing 7.6 pounds, including payload. It has the ability to operate under normal conditio ns at a speed of no more than 45 knots and has the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will operate only in the pilot's or visual observer's visual line of sight at all times. Such operations will insure that the UAS will "not create a hazard to users of the national airspace system or the public." Reform Act Section 333(b). The operators ’ manual will be at the control site w ith the PI C and VO. The DJI Phantom 2 is a Multi

- rotor aircraft weighting 2.9 pounds, including payload. It has and ability to operate under normal conditio ns at a speed of nor more than 35 Knots a nd the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will operate only in the pilot's or visual observer's visual line of sight at all times. Such operations will insure that the UAS will "not create a hazard to users of the national airspace system or the public." Re form Act Section 333(b). The operators’ manual will be at the control site with the PI C and VO. Given the small size of the UAS involved and the restricted environment within which UAs will operate, our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the small size of the UAS s and the low altitudes in which our UAS will operate, approval of the application presents no national security issue. The Inspire 1 can be operated entirely by a touch

- screen, map -based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The Inspire 1 can be operated in both semi and fully autonomous fli ght modes, with the operator simply clicking on a map to create a preplanned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. The UAS has built

- in intelligent fault handling which allows the Inspire 1 to detect a system fault while in the air and automatically fly back to its take off location and land. Faults that can be detected include: loss of communication; loss of GPS lock; and low battery levels. The DJI Phantom 2 UAS is a small and safe sub 3 pound plastic and composite aircraft utilizing four propellers driven by a 5200mAh, 11.1V, LiPo smart battery with an average flight time of 17

- 18 minutes. The remote contro l/transmitter operates at 2.4 GHz. The aircraft’s software can be calibrated to limit both AGL and distance from the transmitter. The aircraft will automaticallyreturn to point of origin or descend in place should signal with the transmitter be lost. The UAS is

unmanned, operates at low altitudes, does not run on combustible fuel, has very low decibel level noise emissions and has a small payload capacity and short flight time, thus significantly reducing current risk levels involved with utilizing manned aircraft for aerial photography. All flight operations are global positioning system (GPS) controlled, making the systems easy to navigate. At any point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS position. Also a flight termination link

- to prevent a "fly away" or other potentially dangerous situation

- is available to the operator.

**DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR Part 21, Subpart H: Airworthiness certificates**  Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by Family Memories Photography. An exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701(f) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requ irement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed. **14 CFR 45.23(b) & 14 CFR 45.29: Marking of the aircraft; Display of Marks; Size of Marks** This regulation requires that certain experimental, provisionally certified aircraft, or light

- sport category aircraft to be marked with letters between 2 inches and 6 inches high "limited", "restricted" "light

- sport," "experimental," or "provisional," near each entrance to a cabin, cockpit or pilot station. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS wi ll have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the UAS, 2 inch lettering will be impossible. Robbins Land Surveying, Inc. Family Memories Photography will mark the UAS with the o rganization's name and address. **14 CFR 61.23: Medical certificates; Requirement and duration** Regulations provide that a person: (1) Must hold a first

- class medical certificate: a) When exercising the pilot

- in

- command privileges of an airline transport p ilot certificate; b) When exercising the second

- in

- command privileges of an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or c) When serving as a required pilot flight crewmember in an operation conducted under part 121 of this chapter if the pilot has reached his or her 60 th birthday. (2) Must hold at least a second class medical certificate when exercising: a) Second

- in

- command privileges of an airline transport pilot certificate in part 12 1 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); orb) Privileges of a commercial pilot certificate

Given the size of the UAS, th eir structure, the limited flight area and the safety features integrated into the autopilot (among others the flight termination system), Family Memories Photography believes that an Equivalent Level of Safety can be reached if the pilot

- in

- command has a valid driver's license. **14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command** Sections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed UAS manufacturers flight training before flying a UAS. Unlike a conventional aircraft that carries the pilot and pas sengers, the UAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the User Guide. The risks associated with the operati on of the small UAS are so diminished from the level of risk associ ated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b). **14 CFR 91.7(a): Civil aircraft airworthiness** The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the User Guide for maintenance and use of safety checklists prior to each flight an equivalent level of safety will b e provided. **14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements** The UAS, given there size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the User Manual at the ground control point where the pilot flying the UAS will have immediate access to it.
**14 CF R 91.103: Preflight action**  This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the User Guide and safety checklists. These actions will provide an equivalent level of safety. **14 CFR 91.109: Flight instruction**  Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, UASs and remotely piloted aircraf t do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety is provided by the fact thatneither a pilot nor pass engers will be carried in the aircraft, the ability to control the UAS via

radio signals from the controller and by the size and speed of the aircraft
**14 CFR 91.119: Minimum safe altitudes** Section 91.119 states persons may operate a helicopter at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA. The sUAS meets this criteria as a helicopter and requests the ability to operate at altitudes up to 400’ AGL. Only in accordance with pre

- obtained consent will the sUAS operate while also maintaining an altitude less than 400’ AGL. For compari son with traditional aircraft and rotorcr aft the sUAS weighs less than 8 lbs, while also preventing potential risks associated with flammable fuel. Lastly the 400’ AGL ceiling limits any ability for the sUAS to interfere with conventional aircraft operating at or above 500’AGL. The equivalent level of safety will be achieved given the size, weight and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Becaus e advance notice to the property owner and any on

- site personnel, as well as the precautions outlined below, all affected individuals will be aware of the planned flight operations. Flight operations will be conducted at least 200 feet from all non

partici pating persons (persons other than the pilot in command (PIC) or visual observer (VO), vessels, vehicles and structures, unless:
1. Barriers or structures are present that sufficiently protect non

-participating persons from debris in the event of an accident . The PIC will ensure that non

-participating persons remain under such protection. If a situation arises where non

-participating persons leave such protection and are within 200 feet of the UAS, flight operations will cease immediately and/or; 2. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and; 3. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 14 CFR 91.119(a). The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be conducted at lease 5 miles from an airport and at least 3 miles from any city or densely populated area. The PIC or VO will provide notification to the local Flight Standards District Office and airport controller of all operations within 5 miles of an airport. The FAA will have advance notice of all operations through the filing of notices

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- airmen. Compared to flight operations with aircraft or rotor craft weighing far more than the UAS proposed herein and carrying flammable fuel, any risk associated with our operations if far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119. **14 CFR 91.121: Altimeter Settings** This r egulation requires each person operating the aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriatealtimeter setting available before departure." As the UAS may not h ave a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator before flight.
**14 CFR 91.151(a): Fuel requirements for flight in VFR conditions**  Section 91.151 states no person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. The sUAS battery powered operational flight time is not able to incorporate a 20 minute reserve window following successful first point of intended landing due to current battery capacity limitations. In order to provid e adequate reserve power for return landing the sUAS will abide by a 12 minute flight time or 20 % of remaining battery power, whichever happens first

. **14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration** The UAS has no cabin, co ckpit or pilot station and is operated without an on

-board pilot. Therefore, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. **14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections** These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribe d in part 43 of this chapter etc " and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Family Memorie s Photography. Maintenance wi ll be performed by the operator pursuant to the Maintenance Manual and the User Guide . An equivalent level of safety will be achieved because these UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and be p ut out of service until proper maintenance and then tested

. As provided in the User Guide, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed on the UA . Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.
**PU BLIC INTEREST**  Approval of exemptions allowing commercial operations of UASs for precision aerial surveys enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible fuel, and carry an on

-board human pilot. In contrast, a UAS weighing 8 pounds and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS wil l carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. Conducting aerial surveys with the DJI Inspire 1 , or the Phantom 2 instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial survey flight operations. By using batter y power and electric motors, both the Inspire 1 and the Phantom 2 produce no air pollution and is a viable, environmentally conscious alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are typically utilized for aerial surveys, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Inspire 1 , and the Phan tom 2 while reducing the carbon footprint of aerial surveys, also reduce noise pollution as the UAS s are propelled by battery powered electric motors rather than an internal combustion engine. **EQUIVALENT LEVEL OF SAFETY** Family Memories Photography proposes th at the exemption requested herein apply to civil aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the curre nt regulatory structure because the proposed operations represent a safety enhancement to the already safe protocols followed by aerial survey operations conducted with helicopters and other conventional aircraft. Family Memories Photography will be bound by the following limitations when conducting its UASs operations under an FAA issued exemption:
1. The UAS will weigh less than 9 pounds and 3 pounds respectively

. 2. Flights will be operated within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operations flight will be 20 minutes. Flights will be terminated at 20% battery power reserve should that occur prior to the 20 minute limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Flight operations will be conduced 5 miles from an airport and at least 3 miles from any city or densely populated area, which are depicted in yellow on VFR sectional charts. 6. Flight operations within 5 miles of an airport require notification and approval from the local Flight S tandards District Office and airport controller. 7. Flight operations will occur during daylight hours and under visual meteorological conditions only. 8. The FAA will have advance notice of all operations through the filing of notices

- to

airmen. 9. Minimum crew fo r each operation will consist of the UAS pilot and visual observer/camera operator. 10. The pilot an d visual observer are trained in the operation of the UAS. 11. The pilot and visual observer will at all times be able to communicate by voice and/or text. 12. Written and/or oral permission from the relevant property holders will be obtained. 13. Flight operations will be conducted at least 200 feet from all non

-participating persons, vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect non

-participating persons from debris in the event of an accident. The pilot will ensure that non

participating persons remain under such protection. If a situation arises where non -participating persons leave such protection and are within 20 0 feet of the UAS, flight operation s will cease immediately and/or b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects andc. Operations near the pilot or visual observer do not present an undue hazard to the pilot or visual observer. 14. If the UAS loses communicat ion or loses its GPS signal, both UAS s have the capability to return to the takeoff point location and land. 15. The PIC will have the capability to abort flight in case of unpredicted obstacles or emergencies.
**PRIVACY** All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place.
**FEDERAL REGISTER SUMMARY** Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

- provide more than adequate justification for the grant of the requested exemptions allowing Family Memo ries Photography to conduct contracted commercial sUAS operations using the DJI Inspire 1 and Phantom 2 for a wide range of industries and applications

. Sincerely ,

Roy & Sue Burnett Owner/President Family Memories Photography 13005 Point Richmond Drive NW Gig Harbor, Washington 98332 253

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