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GREAT PLAINS ETHANOL, LLC

27716 462nd Avenue

Chancellor, SD  57015

July 12, 2005

Rufus Decker, Branch Chief

Nudrat Salik, Staff Accountant

United States Securities and Exchange Commission

Division of Corporate Finance

450 5th Street N.W., Stop 4-5

Washington, DC  20549

  RE:

  Great Plains Ethanol, LLC

  Form 10-KSB for the
  fiscal year ended December 31, 2004 (File No. 0-49779)

Dear Mr. Decker and Ms. Salik:

This
letter responds to your review letter dated June 23, 2005.  Thank you for allowing us a few extra days to
respond to your letter. Please find enclosed your review comments, which we
have outlined as A through B (i-iv), and our comments and/or revised
disclosure.

A.                                   Management’s
Discussion and Analysis

Indebtedness, page 23

2.               Please revise your table of contractual cash
obligations to include estimated interest payments on your debt.  Because the table is aimed at increasing
transparency of cash flow, we believe these payments should be included in the
table. Please also disclose any assumptions you made to derive these amounts.

Our Revised Disclosure:

  Payment due by period

  Contractual
  Obligations

  Total

  Less than

  One Year

  One to

  Three Years

  Four to

  Five Years

  After

  Five Years

  Long-Term Debt Obligations (1)

  27,162,515

  3,544,652

  6.807,200

  6,807,200

  10,003,463

  Electrical Purchase Agreements

  1,171,000

  338,000

  709,000

  124,000

  0

  Natural Purchase Agreements

  2,879,500

  352,600

  705,200

  705,200

  1,116,500

  Related Party Purchase Agreements

  5,577,706

  622,616

  1,142,806

  1,203,419

  2,608,865

  Total
  Contractual Cash Obligations

  36,790,721

  4,857,868

  9,364,206

  8,839,819

  13,728,828

(1) Includes all
principal and interest payments to be made by Great Plains Ethanol, LLC on
existing debt as of December 31, 2004.
Interest payments are based on an annual interest rate of 5.03% on the
$26.5 million note.  This does not
include any amounts for the $6 million revolving credit note or the $3 million
revolving line of credit since there was no principal balance outstanding on
either note as of December 31, 2004.

B.                                     Financial Statements

(i)                                     Balance Sheet page F-23.

3. Given that your Form 8-K filed on February 10, 2005
indicates that the cash distribution of $2,245,200 was not approved by the
Board of Managers until January 26, 2005, it is not clear why you have
accrued for this amount at December 31, 2004.  Please advise.

Our Comment:

The first reason for accruing
this amount at December 31, 2004 is the result of our Operating Agreement
(the “Agreement”) and our Allocation and Distribution Policy (the “Policy”).
Under Section 6.2 of the Agreement, the most recent copy of which can be
found in Exhibit 3.5 of our Form 10-KSB dated December 31, 2004,
we are required to distribute to our Members on an annual basis a minimum of
20% of net cash from operations, provided net cash from operations exceeds
$500,000.00 per year and such distribution does not violate or cause us to
default under any terms of any of our credit facilities or debt instruments.
Because sufficient cash from operations was generated in and attributable to
2004, we declared on January 26, 2005 the $2.245 million distribution.

In addition, when distributions
are declared by our Board of Managers, our Policy requires that all
distributions be made to Members of record as of the last day of the previous
trimester. Under the Agreement and Policy, we have three trimesters in a given
year, the first beginning on January 1, the second beginning on May 1,
and the third and final beginning on September 1. Thus, for example, the
distribution declared on January 26, 2005 (during the first trimester) was
required by our Policy to be made to all Members of record as of December 31,
2004.

This Policy, whereby we make
distributions to Members of record as of the last day of the previous
Trimester, is done primarily for the purpose of treating our Members

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fairly and equitably. The goal is to match
the distribution of cash to the Member to the trimester or period in which it
was earned by us. A distribution declared in the first trimester is usually
based on our cash flow from operations generated in the previous trimester or
final trimester of the previous year. If a Member sells his or her capital units
during the third and final trimester—where record transfer of ownership occurs
on the first day of the next trimester pursuant to Section 4.1(b) of
the Agreement—we are thus able to provide that Member the benefit of owning
those capital units during the third and final trimester, as he or she will be
awarded the distribution. In short, because the Agreement and Policy have the
effect of attributing the $2.245 million distribution to 2004, we accrued this
amount at December 31, 2004.

A second reason for accruing this amount at December 31,
2004 was based on SAB topic 1.B.3 (A). Although this topic relates to dividends
declared by a subsidiary, we felt it analogous and applicable to our situation,
particularly in light of the above discussion. Under this topic, dividends may
be given retroactive effect in the balance sheet when such dividends are
declared subsequent to the balance sheet date, provided appropriate footnote
disclosure is made. Since our distribution was declared on January 26,
2005, we believed that, based on this topic, it needed to be accrued
retroactively to December 31, 2004. We, however, disclosed in a footnote
on page F-14 (second to the last paragraph) of our Form 10-KSB only a
portion of our distribution policy and requirements. When applicable,
additional disclosure will be provided in future filings to comply fully with
this topic.

(ii)                                  Note 2 — Summary of Significant Accounting
Policies, page F-8

4. Please disclose the types of expenses that
you include in the cost of revenues line item and the types of expenses that
you include in the general and administrative expenses line item.  Please also disclose whether you include
inbound freight charge, purchasing and receiving costs, inspection costs,
warehousing costs, internal transfer costs, and the other costs of your
distribution network in the cost of revenues line item. With the exception of
warehousing costs, if you currently exclude a portion of these costs from cost
of revenues, please disclose:

•                  In a footnote the line items that these
excluded costs are included in and the amounts included in each line item for
each period presented, and

•                  in MD&A that your gross margins may not
be comparable to those of other entities, since some entities include all of
the costs related to their distribution network in cost of revenues and others
like you exclude a portion of them from gross margin, including them instead in
a line item, such as general and administrative expenses.

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Our Revised Disclosure:

Cost of Revenues – The primary components of costs of revenues
from the production of ethanol and related co-product, are corn expense, energy
expense (natural gas and electricity), raw materials expense (chemicals and
denaturants), shipping costs on sales, and direct labor costs.

Shipping costs incurred by the Company are recorded as a component of
cost of revenues.  Shipping costs in cost
of revenues include inbound freight charges, purchasing and receiving costs,
inspection costs, warehousing costs, and internal transfer costs.

General and Administrative Expenses – The primary components of general and
administrative expenses are management fee expense, administrative payroll
expense, insurance expense and professional fee expense (legal and audit).

Our Comment:

While the first sentence under the existing disclosure for “Shipping
Costs” under our Form 10-KSB accurately reflects how we account for
shipping costs on the cost of revenues side, the next two sentences do not
accurately reflect how we account for shipping costs on the revenue side.
Shipping costs incurred in the marketing and sale of ethanol and distillers
grains are recorded as a component of cost of revenues. However, shipping costs
in the marketing and sale of ethanol are not deducted from the gross sales
price, but are actually included in the gross sales price. Revenue, in
addition, is recorded based on the gross sales price arranged or provided by
the marketer of distillers grains and the exclusive purchaser of ethanol.

(iii)                               Shipping Costs, page F-8

5.               Please tell us how you calculated that
shipping costs arranged by the marketer should be treated as a reduction of the
gross sales price in recording revenue.
Please also address the following:

•                  Please confirm that all of your ethanol and
by-products are sold by the same marketer;

•                  Please tell us whether the customers receive
invoices with your name on them or with your marketer’s name;

•                  Please tell us whether the customer thinks that they are buying from you
or the marketer;

•                  Please tell us whether the shipping costs are
presented separately on the invoice sent to customers; and

•                  Please tell us the amount of shipping costs
deducted from revenues for each of the 2 years ended December 31, 2004 as
well as the three months ended March 31, 2005.

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Our Comment:

As indicated in “Our Comment”
to paragraph four above, shipping costs relative to the sale of ethanol and
distillers grains are a component of gross revenues and are also a component of
cost of revenues.  Revenue is recorded
based on a gross sales price received by our “marketer” of distillers grains,
Dakota Gold Marketing, and the gross sales price received by the exclusive
purchaser of our ethanol, Ethanol Products, LLC. The gross sales price includes
shipping costs and marketing fees in connection with the sale of ethanol and
distillers grains.  The ethanol produced
at our plant is purchased exclusively by Ethanol Products which, in turn,
markets and sells the ethanol to its customers located throughout the United
States. Distillers grains, on the other hand, are exclusively marketed on an
agency basis by and through Dakota Gold Marketing, which sells the distillers
grains on our behalf to the various purchasers.
Both the ethanol and distillers grains’ marketing arrangements are based
on marketing contracts with Dakota Gold Marketing and Ethanol Products.

With respect to the sale of
distillers grains, a purchaser of distillers grains receives an invoice
directly from Dakota Gold Marketing with Dakota Gold Marketing’s name on
it.  Shipping costs and marketing fees
related to the sale, however, are not included on the invoice sent to the
purchaser, as the only items on the invoice are the sales price, freight
surcharge and any applicable tax.  We
account for these shipping and marketing costs through the use of an on-line
report and payment remittance report provided by Dakota Gold Marketing, which
details the shipping costs, marketing fees and price for sales. Presumably,
based solely on the invoice, a customer who purchases distillers grains
believes that it is purchasing distillers grains from Dakota Gold Marketing.

With respect to the sale of
ethanol, when Ethanol Products, LLC provides us with a shipping/purchase order
for its purchase of ethanol, the order contains a gross sales price. Included
in the gross sales price is an itemization for shipping costs and marketing
fees with respect to the sale. We account for these shipping and marketing
costs through the use of an on-line report provided by Ethanol Products, which
details the actual shipping costs, marketing fees and price for sales.  A customer who purchases ethanol from Ethanol
Products believes it is purchasing ethanol directly from Ethanol Products, as opposed
to us, because the invoice generated by Ethanol Products is between Ethanol
Products and the customer.

Shipping costs relating to
the sale of ethanol, which were included in gross revenues and cost of
revenues, were $659,268 and $600,642 for December 31, 2004 and December 31,
2003, respectfully.  Shipping costs
included in gross revenues and cost of revenues for the three months ended March 31,
2005, were $189,437.

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Shipping costs relating to
the sale of distillers grains, which are included in gross revenues and cost of
revenues, were $2,532,911 and $1,829,539 for December 31, 2004 and December 31,
2003, respectfully.  Shipping costs
included in gross revenues and cost of revenues for the three months ended March 31,
2005, were $910,028.

(iv)                              Property and Equipment page F-l0

6.  Please separately discuss the
types of assets under the Equipment category that fall in each part of the
range disclosed.

Our
Revised Disclosure (changes are underlined):

Property and Equipment.

Property and equipment is
stated at cost.  Significant additions
and betterments are capitalized, while expenditures for maintenance, repairs
and minor renewals are charged to operations when incurred.  Depreciation on assets placed in service is
computed using the straight-line method over estimated useful lives as follows:

  Site Improvements

  40 years

  Buildings

  40 years

  Equipment

  3-20 years

“Site Improvements”
consist of landscaping, additional fencing, and improvements to the roads for
entering and exiting the plant.

“Buildings” consist of
process, mechanical and grain buildings, administrative offices, and sheds.

“Equipment” consists of
grain systems, trucks, mechanical and electrical production and process
equipment, cooling towers, boilers, field sensors, and power supplies.

  ****

  ***

  * * *

In connection with response
to the Commission’s review letter, we acknowledge and understand all of the
following:

1.               That we are responsible for the adequacy and
accuracy of the disclosure in our filing;

2.               That the Commission’s staff comments or
changes to disclosures or responses to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and

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3.               That we may not assert Commission’s staff
comments as a defense in any proceeding initiated by the Commission or any
person on the federal securities laws of the United States.

This concludes our response
to your review letter.  We hope that our
revisions and comments have satisfied your concerns and questions.  We look forward to working with you in
resolving these issues.  If you have any
further questions or comments, or need supplemental documentation, please
contact me at (605) 647-0040, or in my absence, Terry Wastell, Controller.  Thank you.

  Sincerely,

  GREAT
  PLAINS ETHANOL, LLC

  /s/
  Rick Serie

  Rick
  A. Serie, General Manager

  cc:

  Dan
  Loveland, Broin Companies

  Larry
  Ward, Broin Companies

  Terry
  Wastell, Controller

  Chris
  Lent, Woods, Fuller, Shultz & Smith P.C.

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