June 30, 2005

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, DC 20549

Attention: Michael Moran


Re:       Glacier Water Services, Inc. (File No. 1-11012)
          -----------------------------------------------

Dear Mr. Moran:

          The following information is submitted in response to the three
numbered points of your comment letter dated June 20, 2005.

     1.   The Company does not believe it has failed to comply with any rules of
          the American Stock Exchange, and it has not specifically given notice
          to the Exchange that its shareholders' equity is below the listing
          guidelines. It has disclosed that fact in its public reports and
          believes that the Exchange is aware of that fact. The Company is not
          aware of any rules of the Exchange which requires notification to the
          Exchange. Furthermore, the Company has not received any notice from
          the Exchange on this subject.

     2.   The Company values its repair parts at the lower of cost or market and
          the disclosure on page 26 regarding repair parts should have been so
          stated. The Company will correct this oversight in future filings. The
          Company utilizes repair parts on a FIFO basis. With respect to the
          utility of the parts in conjunction with the upgrade to newer
          machines, the Company is able to utilize repair parts for both the old
          and the new upgraded machines. Additionally, management periodically
          analyzes repair parts on a regular basis for the existence of either
          excess or obsolete parts.

     3.   The disclosure relating to stock option plans in the 10-K will be
          revised in future filings to segregate the exercise prices into more
          discrete ranges to provide more meaningful information concerning the
          number of shares in each range.

The Company acknowledges that it is responsible for the adequacy and accuracy of
the disclosures in the Company's filing. The Company also acknowledges that the
comments above do not foreclose the Commission from taking action with respect
to the filings and that the Company 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.

                                               Very truly yours,



                                               W. David Walters
                                               Senior Vice President,
                                               Chief Financial Officer