CODE OF ETHICS
                          FOR SENIOR FINANCIAL OFFICERS
                                       OF
                       CHUGACH ELECTRIC ASSOCIATION, INC.


         This Code of Ethics is promulgated by the Board of Directors of Chugach
Electric Association, Inc. (Association) under Section 406 of the Sarbanes-Oxley
Act of 2002 and the rules of the SEC promulgated thereunder and applies to the
Senior Financial Officers of the Association. For this purpose, Senior Financial
Officers means the Chief Executive Officer, the Chief Financial Officer and the
Chief Accounting Officer. This Code contains standards reasonably necessary to
promote: honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional relationships;
full, fair, accurate, timely, and understandable disclosure in the periodic
reports required to be filed by the Association and in other public
communications; and compliance with applicable governmental laws, rules and
regulations. It should be read in conjunction with the Association's Conflict of
Interest policies.

         Senior Financial Officers of the Association must:

         1. Act with honesty and integrity, ethically handling actual or
         apparent conflicts of interest in personal and professional
         relationships. They should recognize that even the appearance of a
         conflict of interest can damage the Association. A conflict of interest
         may exist because of a relationship of theirs or of a family member
         that is inconsistent with the Association's best interests or could
         cause a conflict with their ability to perform their job
         responsibilities.

         2. Report to the Chairman of the Finance Committee any transaction that
         reasonably could be expected to give rise to a conflict of interest.

         3. Produce, or cause to be produced, full, fair, accurate, timely, and
         understandable disclosure in reports and documents that the Association
         files with or submits to the Securities and Exchange Commission and in
         other public communications.

         4. Comply with applicable governmental laws, rules and regulations.

         5. Promptly report any violation of this Code of Ethics to the Chairman
         of the Finance Committee.

         The Association reserves the right to determine when actual or
potential conflicts of interest exist, and then to take any action, which in the
sole judgment of the Association, is needed to prevent the conflict from
continuing.

         Senior Financial Officers will be held accountable for their adherence
to this Code of Ethics. Their failure to observe the terms of this Code of
Ethics may result in disciplinary action, up to and including immediate
termination of your employment.

         Any request by a Senior Financial Officer for a waiver of any provision
of this Code of Ethics must be in writing and addressed to the Chairman of the
Finance Committee. The Board will have the sole and absolute discretionary
authority, acting upon such recommendation as may be made by the Finance
Committee, to approve any waiver from this Code of Ethics. Any waiver for this
Code of Ethics for Senior Financial Officers will be disclosed promptly on Form
8-K or any other means approved by applicable SEC rules or listing standards.

         Nothing contained in this Code of Ethics is intended by the Company to
be, nor shall it be construed as, an employment agreement.

         This Code of Ethics was approved by the Board of Directors at its
regular board meeting on June 16, 2004.



Date: June 16, 2004                                      By /s/ Pat Jasper
                                                         Secretary of the Board