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September 21, 2005

United States Securities and Exchange Commission

Attn:  Jeffrey Gordon, Division
of Corporation Finance

100 F Street, N.E., Stop 7010

Washington, D.C. 20549

RE:          Form 10-KSB for the
fiscal year ended December 31, 2004

Form 10-QSB for the quarters ended March 31
and June 30, 2005

File No. 333-96703

Dear Mr. Gordon:

As the principal executive officer and principal financial officer, we
provide the following response to your inquire dated September 14, 2005.

FORM 10-KSB
FOR THE YEAR ENDED DECEMBER 31, 2004

Item 8A – Controls and Procedures, page 46

1.     You
currently disclose in your Form 10-KSB, as well as your Forms 10-QSB for
the periods ended March 31, 2005 and June 30, 2005, that your
principal executive officer and principal financial officer have concluded that
your disclosure controls and procedures are effective, except for material
weaknesses in your internal controls.
Given the exceptions noted, it remains unclear whether your principal executive
officer and your principal financial officer have concluded that your
disclosure controls and procedures are effective.  Please revise your disclosure to state, in
clear and unqualified language, the conclusions reached by your principal
executive officer and principal financial officer on the effectiveness of your
disclosure controls and procedures.
Please confirm if your principal executive officer and principal
financial officer have concluded that your disclosure controls and procedures
were effective as of December 31, 2004, March 31, 2005 and June 30,
2005.  Otherwise you should amend your Form 10-KSB
and Forms 10-QSB to disclose that given the identified matters, your disclosure
controls and procedures are not effective.

RESPONSE

The principal executive officer and principal
financial officer hereby confirm to the SEC all disclosure controls and
procedures were deemed to be effective as disclosed in the Form 10-KSB and
Forms 10-QSB for the periods ended December 31, 2004, March 31, 2005
and June 30, 2005.

FORM 10-QSB
FOR THE PERIOD ENDED JUNE 30, 2005

Financial Statements

Note 1 - Summary of Significant Accounting
Policies, page 8

2.     In
future filings, please disclose your revenue recognition policy.  In doing so, please also disclose whether
your stated shipping terms are FOB shipping point or FOB destination pursuant
to your sales agreements with customers.

RESPONSE

The following is our proposed revenue
recognition disclosure that will also be included in future filings.

Revenue from the production of ethanol and
related products is recorded upon transfer to our customers.  The transfer takes place at the plant site
and therefore shipping terms are FOB shipping point.  Interest income is recognized as earned.  Income from federal and state incentives are
recognized based on fulfillment of program criteria, completion of application
and pro-ration factors posted by the sponsoring organization.

Note 2 - Incentive Receivable, page 9

3.     You
disclose that when it is uncertain that you will receive full allocation and
payment due under the federal incentive program, you derive an estimate based
on various factors including the most recently used payment factor applied to
the program.  Given that this is the
first quarter in which you derived revenues, please tell us how you concluded
that the estimated revenues due under the federal incentive program were
reasonably determinable, since you have no historical experience to base your
estimates on.  See paragraph 6.98 of the
AICPA Audit and Accounting Guide for Agricultural Producers and Agricultural
Cooperatives.  In addition, please tell
us how much of the June 30, 2005 incentive receivable has been collected
to date.

RESPONSE

Management determines the federal incentive
revenue based upon the USDA approved calculation and applies the most recently
posted pro-ration factor as made available on the USDA website.  On September 9, 2005 we received
$81,030.07.  The amount received varies
from the accrual due to the quarterly pro-ration factor being reduced from
50.0617% to 36.4201%; the reduced pro-ration factor was not available at June 30,
2005 or at the time of our filing.

Note 3 – Property and Equipment, page 10

4.     The
range of useful lives for your property and equipment is very broad.  In future filings, please separately disclose
the range of useful lives for each category of property and equipment presented
on your balance sheet.  For categories
that still have very broad useful lives, you should discuss the types of assets
that fall in each part of the range.

RESPONSE

Management agrees to separately disclose the
range of useful lives by category in future filings.  Future disclosures are expected to be:

Depreciation is computed over the estimated
useful life of each asset using the straight-line method.  Estimated useful lives generally used in
computing depreciation are:

  Land improvements

  15 to 20 years

  Buildings

  40 years

  Machinery and equipment

  7 to 15 years

  Office equipment

  5 to 10 years

  Computers and software

  3 to 5 years

  Vehicles

  5 years

Note 11 – Commitments and Contingencies, page 14

5.     Please
tell us in a letter whether you had accrued the $300,000 settlement in your June 30,
2005 financial statements.  Please
address your compliance with SFAS 5.

RESPONSE

The $300,000 settlement was accrued at June 30,
2005 and included in the balance sheet caption Accounts Payable – Related Parties.  The commitment was accrued in satisfaction of
SFAS No. 5, Accounting for Contingencies, which requires accrual of
contingencies if both of the following conditions are met:

1.             Information
is available prior to financial statement issuance indicates that it is
probable that a liability incurred at the date of the financial statements.

2.             The
amount of the liability is reasonably estimable.

Management is of the opinion a liability had been
incurred as a significant portion of the dirt had already been removed.  Management was negotiating the settlement and
believed the $300,000 to be a reasonable estimate.

We acknowledge that:

•      We
are responsible for the adequacy and accuracy of the disclosure in our 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

•      We
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.

  /s/ William Pracht

  William Pracht

  Principal Executive Officer

  /s/ Thomas Leitnaker

  Thomas Leitnaker

  Principal Financial Officer