Exhibit 8.1


                     [Letterhead of Meserli & Kramer P.A.]


December 20, 2002

The Board of Governors
Granite Falls Community Ethanol Plant, LLC
2448-540th Street, Suite 1
Granite Falls, Minnesota  56241

     RE:      2002 Registration Statement Tax Matters

Ladies and Gentlemen:

As counsel for Granite Falls Community Ethanol Plant, LLC (the "Company"), we
furnish the following opinion in connection with the proposed issuance by the
Company of up to 30,000 of its membership units (the "Units").

We have acted as legal counsel to the Company in connection with its offering of
the Units. As such, we have participated in the preparation and filing with the
Securities and Exchange Commission under the Securities Act of 1933, as amended,
of a Form SB-2 Registration Statement originally dated August 30, 2002 relating
to that offering (the "Registration Statement").

You have requested our opinion as to matters of federal tax law that are
described in the Registration Statement. We are assuming that the offering will
be consummated and that the operations of the Company will be conducted in a
manner consistent with that described in the Registration Statement. We have
examined the Registration Statement and such other documents as we have deemed
necessary to render our opinion expressed below.

Based on the foregoing, all statements as to matters of law and legal
conclusions contained in the Registration Statement under the heading "Income
Tax Consequences of Owning Our Membership Units" reflect our opinion unless
otherwise noted. That section of the Registration Statement is a general
description of the principal federal income tax consequences that are expected
to arise from the ownership and disposition of Units, insofar as it relates to
matters of law and legal conclusions. That section also addresses material
federal income tax consequences to prospective unit holders of the ownership and
disposition of Units.

Our opinion extends only to matters of law and does not extend to matters of
fact. With limited exceptions, the discussion relates only to individual
citizens and residents of the United States and has limited applicability to
corporations, trusts, estates or nonresident aliens. The opinion expressed
herein is effective only as of the date of this opinion letter. The opinion set
forth herein is based upon known facts and existing law and regulations, all of
which are subject to change prospectively and retroactively. We assume no
obligation to revise or supplement such opinions as to future changes of law or
fact.

An opinion of legal counsel represents an expression of legal counsel's
professional judgment regarding the subject matter of the opinion. It is neither
a guarantee of the indicated result nor is an undertaking to defend the
indicated result should it be challenged by the Internal Revenue Service. This
opinion is in no way binding on the Internal Revenue Service or on any court of
law.

We consent to the filing of this opinion as an exhibit to the Registration
Statement and to the reference to our firm in the Registration Statement.

Very truly yours,


/s/ Messerli & Kramer P.A.

MESSERLI & KRAMER P.A.