-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, RXyL6zqk0vi0LWGUrhTGmhC6SHaNdhSmYBYqhaKz8bHGW2QtH+izbCaV1bu6G4Dl ICJGtoHMwM2L+akraM3/1A== 0000000000-05-039565.txt : 20060926 0000000000-05-039565.hdr.sgml : 20060926 20050801161444 ACCESSION NUMBER: 0000000000-05-039565 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050801 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: CHUGACH ELECTRIC ASSOCIATION INC CENTRAL INDEX KEY: 0000878004 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRIC SERVICES [4911] IRS NUMBER: 920014224 STATE OF INCORPORATION: AK FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 5601 ELECTRON DR STREET 2: PO BOX 196300 CITY: ANCHORAGE STATE: AK ZIP: 99518 BUSINESS PHONE: 9075637494 MAIL ADDRESS: STREET 1: 5601 ELECTRON DRIVE CITY: ANCHORAGE STATE: AK ZIP: 99518 PUBLIC REFERENCE ACCESSION NUMBER: 0000878004-05-000005 LETTER 1 filename1.txt Mail Stop 3561 August 1, 2005 By Facsimile and U.S. Mail Mr. Evan J. Griffith Chief Executive Officer Chugach Electric Association, Inc 5601 Electron Dr. Anchorage, Alaska 99518 Re: Chugach Electric Association, Inc Form 10-K for the year ended December 31, 2004 Filed March 31, 2005 File No. 3-42125 Dear Mr. Griffith: We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated July 21, 2005. Our review resulted in the following accounting comments. As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file. 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. 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. 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. 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. ``````````````````````````````````````````````` If you have any questions regarding these comments, please direct them to John Cannarella, Staff Accountant, at (202) 551-3337 or, in his absence, to the undersigned at (202) 551-3849. Any other questions regarding disclosure issues may be directed to H. Christopher Owings, Assistant Director, at (202) 551-3725. Sincerely, Jim Allegretto Sr. Assistant Chief Accountant ` ?? ?? ?? ?? Mr. Evan J. Griffith Chugach Electric Association, Inc. August 1, 2005 Page 2 -----END PRIVACY-ENHANCED MESSAGE-----