SecProbe.io

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Mail Stop 7010

September 29, 2005

Via U.S. mail and facsimile

J.F. Robertson
Chief Executive Officer
United Wisconsin Grain Producers, LLC
W1231 Tessman Road
Cambria, Wisconsin  53923

	RE:	Form 10-KSB for the fiscal year ended December 31, 2004
Forms 10-QSB for the fiscal quarters ended March 31, 2005 and June
30, 2005
			File No. 0-50733

Dear Mr. Robertson:

		We have reviewed your filings and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Where indicated, we
think you should revise your document in future filings 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
information so we may better understand your disclosure.  After
reviewing this information, we 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Item 6. Management`s Discussion and Analysis, page 14

Application of Critical Accounting Policies, page 19
1. In future filings, please include a discussion and analysis of
your critical accounting estimates that does not repeat your
significant accounting policies included in Note 1, but rather
address the factors considered and assumptions used in making
these
critical estimates and the potential impact on the financial
statements if actual results differ from your assumptions.
Specifically, your disclosure should address your methodology for
fair valuing your derivative instruments.  Regarding your
disclosure
in your Form 10-QSB for the fiscal quarter ended June 30, 2005,
your
disclosure should explain in sufficient detail how you arrived at
your estimate of the incentives you have earned from the Commodity
Credit Bioenergy Program.  Refer to Financial Reporting Policy 60
and
Proposed Rule 33-8098 for guidance.  In your response, please tell
us
what your disclosures will look like in future filings.

3. Bank Financing, page 31
2. In future filings, please include a discussion of your material
financial debt covenants, including the actual ratio amounts for
each
of the periods presented, unless you believe that the likelihood
of
default is remote.  See Section 501.03 of the Financial Reporting
Codification.  Please also tell us if you have violated any of
your
financial debt covenants during fiscal years 2003 and 2004 and
your
interim periods for the three-months ended March 31, 2005 and June
30, 2005, including a discussion of any waivers obtained, if
necessary.

9.  Commitments and Contingencies, page 33
3. Regarding the unasserted claim, please address the following:
* Please tell us with a view toward future disclosure what the
issue
is surrounding the unasserted claim.  Also tell us the current
status
of this unasserted claim.
* We note that you are unable to estimate the potential liability.
You further comment that you believe the liability will not have a
material adverse effect on your financial position.  Please tell
us
with a view toward future disclosure how you concluded that this
contingency will not be material to your financial position if you
are unable to estimate the potential liability.
* Please tell us with a view toward future disclosure the
potential
effect of this contingency on your financial position and
liquidity.
* Please note that a statement that a contingency is not expected
to
be material does not satisfy the requirements of SFAS 5 if there
is
at least a reasonable possibility that a loss exceeding amounts
already recognized may have been incurred and the amount of that
additional loss would be material to a decision to buy or sell
your
securities.  As such, please either disclose the estimated
additional
loss or range of loss that is reasonably possible, or disclose
that
such an estimate cannot be made.  Refer to paragraph 10 of SFAS 5
for
guidance.
* Please include disclosure for this unasserted claim in all
future
filings, including your interim financial statements.  Refer to
Instruction 2(2)(ii) to Item 310(b) of Regulation S-B for
guidance.

Item 8A.  Controls and Procedures, page 35
4. We note that your chief executive officer and chief financial
officer concluded your disclosure controls and procedures "...are
effective in ensuring that material information related to us is
recorded, processed, summarized and reported within the time
periods
required by the forms and rules of the Securities and Exchange
Commission."  This is an incomplete definition of disclosure
controls
and procedures per Rules 13a-15(e) and 15d-15(e) of the Exchange
Act.
Please confirm to us and revise in future filings your disclosure
to
clarify, if true, that your officers concluded that your
disclosure
controls and procedures are effective to ensure that information
required to be disclosed by you in the reports that you file or
submit under the Exchange Act is recorded, processed, summarized
and
reported, within the time periods specified in the Commission`s
rules
and forms and to ensure that information required to be disclosed
by
an issuer in the reports that it files or submits under the
Exchange
Act is accumulated and communicated to your management, including
its
principal executive and principal financial officers, or persons
performing similar functions, as appropriate to allow timely
decisions regarding required disclosure.  Refer to Exchange Act
Rules
13a-15(e) and 15d-15(e) for the full definition of disclosure
controls and procedures.

Exhibits, page 40
5. In future filings, please ensure that your certifications
required
under section 302 of the Sarbanes-Oxley Act conform exactly to the
language per Release Number 33-8238.  Specifically refer to 4.c.
of
your 302 certifications.

Form 10-QSB for the Fiscal Quarter Ended June 30, 2004

1. Summary of Significant Accounting Policies, page 9

Inventories, page 10
6. In future filings, please state your inventory costing method.

Derivative Instruments, page 10
7. We note that you are required to maintain cash balances related
to
your derivative instrument positions, which you have classified as
restricted cash and are including such amount in cash and cash
equivalents on the face of the balance sheets and are also
including
such amounts in the beginning and ending balances of cash and cash
equivalents on the statements of cash flows.  In future filings,
please revise your statements of cash flow presentation to not
include restricted cash in the beginning and ending balances of
cash
and cash equivalents.  Refer to paragraph 7 of SFAS 95 for
guidance.

*    *    *    *

      Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please file your letter on EDGAR as a
correspondence file.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* 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.

	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 our review of your filing or in
response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Meagan Caldwell, Staff Accountant, at (202) 551-
3754
or, in her absence, Tracey Houser at (202) 551-3736.

							Sincerely,

							Nili Shah
							Accounting Branch Chief

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Mr. J.F. Robertson
United Wisconsin Grain Producers, LLC
September 29, 2005
Page 1 of 5

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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