March 3, 2005


Mail Stop 0510

Via U.S. mail and facsimile

Mr. Barry A. Ellsworth
Green Plains Renewable Energy, Inc.
9635 Irvine Bay Court
Las Vegas, NV 89147


Re: 	Green Plains Renewable Energy, Inc.
Form S-1/A filed February 28, 2005
File No. 333-121321


Dear Mr. Ellsworth:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Business, page 31
Our Primary Competition, page 40

1. We note your new risk factor on page 16.  Please expand your
disclosure in this section to discuss competition from foreign
producers of ethanol.

Report of Independent Registered Public Accountants, page F-1

2. We have read your response to our comment 8.  Your response
indicates that you auditor`s report has been revised to indicate
that
they conducted their audit in accordance with "the standards of
the
Public Company Accounting Oversight Board (United States)" rather
than in accordance with "auditing standards of the Public Company
Accounting Oversight Board (United States)."  However, it does not
appear that this change has been made in the auditor`s report
included in this filing on Form S-1/A.  Please obtain and include
from your auditors a revised opinion.  Refer to PCAOB Standard No.
1,
Exhibit 2.

3. We have read your response to our comment 9.  While the revised
audit report obtained from your auditors has dual dated the
effects
of the restatements as described in Note 5, it does not reference
the
restatement to record stock-based compensation, the
reclassification
of the deposit in your statement of cash flows, and the footnote
that
discusses each in greater detail within the audit report itself.
Please obtain and include in your amended filing, an updated
opinion
from your auditors, as well as an updated consent.

Statement of Cash Flows, page F-5

4. Your statement of cash flows does not present the $37,500
adjustment relating to stock-based compensation required to
reconcile
the net loss to the net cash used by operating activities.  Please
revise to include this.  Refer to paragraphs 28 and 29 of SFAS 95.

Exhibit 23.1, Consent of L.L. Bradford & Company, LLC

5. We have read your response to our comment 9.  Your updated
consent
from your auditors references their consent in the registration
statement filed on Form S-1.  Please obtain and include an updated
consent from your auditors which references their consent to your
registration statement filed on Form S-1/A.

*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter that is filed on EDGAR with your amendment that keys
your responses to our comments and provides any requested
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

	the company may not assert staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.




      You may contact Meagan Caldwell, Staff Accountant, at (202)
824-5578 or, in her absence, Rufus Decker, Accounting Branch
Chief,
at (202) 942-1774 if you have questions regarding comments on the
financial statements and related matters.  Please contact Andrew
Schoeffler, Staff Attorney, at (202) 824-5612 or, in his absence,
the
undersigned at (202) 942-2864 with any other questions.

Sincerely,



Jennifer Hardy
Branch Chief


cc:	Eric L. Robinson, Esq.
Blackburn & Stoll, LC
257 East 200 South, Suite 800
Salt Lake City, UT 84101
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Mr. Barry A. Ellsworth
Mach 3, 2005
Page 1 of 4





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE