30 Rockefeller Plaza, New York, NY 10112 tel 212-408-5100 fax 212-541-5369 [GRAPHIC OMITTED] CHADBOURNE & PARKE LLP PHILIP L. COLBRAN DIRECT TEL (212) 408-1122 pcolbran@chadbourne.com February 7, 2005 Securities and Exchange Commission 450 Fifth Street, N.A. Washington, D.C. 20549 Re: Amendment No. 1 to Registration Statement on Form S-4 of Ormat Funding Corp. (the "Registrant"); and Brady Power Partners, OrMammoth Inc., Ormesa LLC, ORNI 1 LLC, ORNI 2 LLC, ORNI 7 LLC, Steamboat Development Corp. and Steamboat Geothermal LLC (collectively the "Co-Registrants") Ladies and Gentlemen: On behalf of the Registrant and the Co-Registrants we transmit herewith for filing in accordance with the Securities Act of 1933, as amended, an Amendment No. 1 to the Registration Statement on Form S-4 (the "Registration Statement") relating to the Registrant's $190,000,000 aggregate principal amount 8 1/4% Senior Secured Notes due 2020 (the "Notes") and guarantees of such Notes by the above-named Co-Registrants, each of which is a wholly-owned subsidiary of the Registrant. The Registrant previously transferred the required filing fee to the account of the Securities and Exchange Commission at the U.S. Treasury designated lockbox depository at Mellon Bank on December 23, 2004 in connection with the Registrant's initial filing of the Registration Statement on Form S-4. The securities covered by the Registration Statement will be issued in an exchange offer to be conducted by the Registrant and the Co-Registrants. A letter from the Registrant indicating its reliance on the no-action letters issued to Exxon Capital Holding Corporation (publicly available April 13, 1989), Morgan Stanley & Co., Inc. (publicly available June 5, 1991) and Shearman & Sterling (publicly available July 2, 1993) was submitted on December 23, 2004 in connection with the Registrant's initial filing of the Registration Statement on Form S-4. [GRAPHIC OMITTED] Securities and Exchange Commission February 7, 2005 -2- Please address any comments or questions regarding this filing to Philip Colbran (tel: (212) 408-1122) at this firm. Very truly yours, /s/ Philip L. Colbran Philip L. Colbran VIA EDGAR - --------- Attachments
