SecProbe.io

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Mr. John Cannarella
Staff Accountant
Securities and Exchange Commission
Washington, D.C. 20549
United States of America

August 12, 2005

Dear Mr. Cannarella,

RE:      Form 10-K for the year ended December 31, 2004
YOUR RE: File No. 3-42125

We refer to your comment letter dated August 1, 2005, requesting further
information in relation to the above Form 10-K, filed on March 31, 2005.

Attached please find our response to your comment letter, containing the
supplemental information to the aforesaid Form 10-K, in response to your
request.

We acknowledge that Chugach Electric Association, Inc. is responsible for the
adequacy and accuracy of the disclosure in the filing; staff comments or changes
to disclosure in response to staff comments do not foreclose the Commission from
taking any action with respect to the filing; and Chugach Electric Association,
Inc. may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United
States.

We look forward to receiving your confirmation that our response meets your
requirements.

Sincerely,

/s/ Evan J. Griffith
Evan J. Griffith
Chief Executive Officer
Chugach Electric Association, Inc.
5601 Electron Dr.
Anchorage, AK 99518

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FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations

     Patronage Capital (Equity)

1.            We note your response to comment 5 of our letter dated July 7,
              2005. You disclose in 2004 that you authorized the retirement of
              $3,126,560 of retail patronage and $125,000 for capital credits.
              Please clarify why the sum of such authorized amounts totaling
              $3,251,560 exceeds the $3,193,600 reflected as retirement of
              capital credits and estate payments as a financing cash outflow
              for the year ended December 31, 2004.

              All retirements of capital credits, which include amounts retired
              under a new discounted capital credits retirement plan, and estate
              payments originate with the amount authorized by the Company's
              board of directors. That amount, however, may be reduced due to
              several reasons. The Company may reduce a member's capital credits
              to recover a bad debt or if a member's previous capital credits
              were classified as unclaimed pursuant to section 34.45.200 of
              Alaska's unclaimed property law or if a member's capital credit
              retirement is less than $5, the minimum amount required to issue a
              check. The amount authorized by the Company's board of directors
              in November and December of 2004 was reduced for the reasons
              listed above.

Notes to Financial Statements

     Note 1. Description of Business and Significant Accounting Policies

     2.       We note your response to comment 7 of our letter dated July 7,
              2005. Please include a more detailed description of your impaired
              assets and the facts and circumstances leading to the impairment
              as required by paragraph 26(a) of SFAS 144.

              The impaired assets were five PC25 Model C fuel cells. They were
              packaged, self contained, 200 kW units, which operated using
              pipeline natural gas fuel and provided on-site electricity and
              heat in connection with the Company's utility grid. The fuel cells
              were intended to generate power for the benefit of the United
              States Postal Service (USPS). In the second quarter of 2003 during
              discussions between the Company and the USPS it was determined
              that it was more likely than not that the fuel cells would no
              longer be used to generate power for the benefit of the USPS.
              Additionally, it was unlikely that the fuel cells could or would
              be sold, and more likely the fuel cells would be taken out of
              service. In July 2003, prior to the issuance of the Company's Form
              10Q, we committed to a plan to abandon the asset. In accordance
              with SFAS No. 144, paragraph 28, the Company adjusted the
              remaining depreciable life of the asset. Future filings with the
              Commission will contain expanded disclosure of this information to
              promote reader understanding.

     3.       We note your response to comment 9 of our letter dated July 7,
              2005. Your existing disclosure suggests you only record revenues
              on an "as billed" basis. Please clarify your disclosure to
              indicate that you accrue for retail unbilled revenue. In doing so,
              please quantify the amounts of your unbilled revenues as required
              by Rule 5-02 (3) of Regulation S-X.

              The Company does accrue for unbilled retail revenue. To insure we
              recognize a full year's revenue on the financial statements, the
              Company recognizes unbilled retail revenue through a monthly
              retail revenue adjustment process that adjusts retail revenue for
              overages or underages in meter read intervals to reflect a
              calendar month read. Wholesale revenue is recorded from metered
              locations, so no accrual is made. The Company accrued $1,072,175
              of unbilled retail revenue at December 31, 2004, which was
              subsequently billed in January 2005. Future filings with the
              Commission will clarify the Company's disclosure concerning retail
              unbilled revenue, including disclosure of the amounts accrued, and
              will contain expanded disclosure of this information to promote
              reader understanding.

     Note 8. Debt

     4.       We note your response to comment 12 of our letter dated July 7,
              2005. You should provide current and maximum interest rates
              applicable to your auction rate series B bond in future filings.
              In this regard, we understand that the rate on such bonds is reset
              every 28 days such that a market rate is maintained. If otherwise,
              please clarify our understanding. If so, advise how the rate is
              determined and whether and how it results in the bonds fair value
              being equal to its face amount.

              The bonds are repriced every 28 days at auction, which determines
              the market rate. The maximum rate is 15%. Future filings with the
              Commission will include this disclosure and disclosure of current
              and maximum rates related to these bonds.

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