Documents

I have documented elsewhere herein my efforts to obtain hard information (not platitudes, generalities, and apologies about just how darn complex it all is) concerning the various transactions surrounding the City's foray into public power. We were told in mid-December that we would receive a response from Coleen Balzarini's office with the requested information. As of this morning, we have received nothing.

While there is no doubt quite a lot of information, wouldn't you think that on a project of this magnitude that the administrators would have a fairly centralized packet of documents containing the fundamentals of the transaction? Wouldn't you anticipate a great deal of public interest, and that at least some members of the public might want to read the contracts and other documents for themselves? I can't believe it has taken this long to get information.

So, this morning, the following letter was hand-delivered to the Civic Center:

Ms. Coleen Balzarini
Fiscal Services Director
City of Great Falls
P.O. Box 5021
Great Falls, MT 59401 HAND DELIVERED

Re: Electric City Power/SME

Dear Ms. Balzarini:

I am writing to obtain information regarding the City of Great Falls involvement with Electric City Power, Inc., and its relationship to and involvement with Southern Montana Electric Generation and Transmission Cooperative.

I note that we first began requesting this information from your office on approximately December 11, 2006. My paralegal spoke with a representative of your staff on December 14, 2006, and was told we would be called when the documents were ready for us. She spoke with the representative again the following day, and was informed that it would take a while since all of the information was not contained in a central file or location. To date we have not heard from any representative of your office.

Specifically, we would like to obtain, at your earliest convenience, the following documents. If they are extremely voluminous, please advise and we will inspect them prior to copying:

· All organizational documents for Electric City Power, including financial documents showing capitalization.

· All contracts or other documentation of the relationship between ECP and other utility members of SME.

· All contracts between SME and individuals for services.

· Documents demonstrating the flow of money between the City of Great Falls and ECP and SME, as well as between ECP and SME.

· Any and all agreements, memoranda, etc., between the City of Great Falls and ECP and SME, as well as between ECP and SME including, but not limited to, all documents evidencing any joint venture or other ownership interest between or in ECP and/or SME.

· Any and all construction estimate document cover sheets and correspondence.

· All feasibility studies including, but not limited to, the one authorized by the City of Great Falls in the Commission Meeting on November 4, 2003.

Thank you for your attention to this matter. I look forward to hearing from you at your convenience.