[LETTERHEAD OF PACIFIC ETHANOL, INC.]




December 1, 2005

VIA EDGAR CORRESPONDENCE
- ------------------------

Securities and Exchange Commission
100 F. Street, N.E.
Mail Stop 7010
Washington, DC 20549-7010

     Re:  Pacific Ethanol, Inc., Reg. No. 333-127714
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Ladies and Gentlemen:

     The Securities and Exchange Commission is hereby notified that Pacific
Ethanol, Inc. (the "Company") requests pursuant to Rule 461(a) of Regulation C
that Amendment No. 3 to Registration Statement on Form S-1 be declared effective
at 5:00 p.m. Eastern daylight time on December 1, 2005, or as soon as
practicable thereafter.

     In connection with the above request, please be advised that the Company
hereby acknowledges the following:

     o    should the Securities and Exchange Commission (the "Commission") or
          the staff of the Commission (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;

     o    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

     o    the Company may not assert 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.

                                         Very truly yours,

                                         PACIFIC ETHANOL, INC.


                                         By: /s/ NEIL M. KOEHLER
                                            ---------------------------------
                                                 Neil M. Koehler
                                                 Chief Executive Officer