[CBUTTARS 3/10/2020 9:45:50 AM]

”Company Comments:



Determining a per share quantity valuation for Smithfield Irrigation Company entails
significant complexity and uncertainty. The Kimball Decree provided for 33.5 cfs from
Smithfield Creek (i.e., Summit Creek) `for the irrigation of 2944 acres.` This acreage,
together with sole supply under the Company`s well rights and its owned shares in the
Cache Highline Water Association would provide for approximately 1 acre/share. The
Proposed Determination and previous change application approvals provide for around 0.77
to 0.81 acres/share. Finally, the Company`s Bylaws provide for `approximately 3.0
acre-feet and no more than 4.0 acre-feet per irrigation season.` Without prejudice to
the Company`s right to claim and use the full extent of its water rights, and to avoid
adverse impacts to shareholders within the Company`s water systems, the Company has
determined that any share statements should be based on 0.75 acres and 3 acre-feet per
class A share of stock in the Company.”



For additional information, see the ”Attachment to Water Company Database Summary for
Smithfield Irrigation Company” received on March 9, 2020 - scanned to 25-6109.