SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

March 19, 2008

Via U.S. mail and facsimile

Mr. Jerry L. Peters
Chief Financial Officer
Green Plains Renewable Energy, Inc.
105 North 31st Ave., Suite 103
Omaha, Nebraska 68131

 RE: Form 10-K for the fiscal year ended November 30, 2007
   File No. 1-32924

Dear Mr. Peters:

  We have reviewed these filings a nd have the following comments.  If you
disagree with a comment, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with supplemental
information so we may better understand your  disclosure.  After reviewing this
information, we may or may not raise additional comments.

 Please understand that the purpose of our re view 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 on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED NOVEMBER 30, 2007

General

1. Where a comment below requests additional disclosures or other revisions to be
made, please show us in your supplemental response what the revisions will look like.
These revisions should be included in your future filings.

Mr. Jerry L. Peters
March 19, 2008
Page 2 of 4
Item 7.  Management’s Discussion and Analysis

Overview

Superior plant, page 33

2. You state that you believe you have sufficient funds available to complete the
construction and commence operations of the Superior plant.  You disclose the projected cost of this plant to be $95.7 million.  In your discussion of liquidity and
capital resources on page 38, you disclose that you have $11.9 million in cash and equivalents and $31.6 million av ailable under committed loan agreements.  In light of
your current contractual oblig ations, please expand your disclosure to address how
you determined you have sufficient funds avai lable to complete the construction of
the Superior plant and commence operations.

Liquidity and Capital Resources

Contractual Obligations, page 42

3. Please separately present estimated intere st payments on your debt.  Please also
disclose any assumptions you made to derive these amounts.

Financial Statements

Consolidated Statements of Cash Flows, page F-7

4. Please tell us how you determined it was appr opriate to reflect th e payment of utility
services deposits as cash flows from invest ing activities instead of cash flows from
operating activities in accord ance with paragraphs 15 through 17 of SFAS 95.  Your
response should explain the terms of the deposit, including whether the deposit is
refundable as well as whether this deposit wi ll be applied to amounts owed for future
usage of utility services.

Note 1.  Description of Business and Summar y of Significant Acc ounting Policies, page
F-9

General

5. Please disclose the types of expenses that you include in the cost of goods sold line
item and the types of expenses that you incl ude in the operating expenses line item.
Please also disclose whether you include inbound freight charges, purchasing and receiving costs, inspection co sts, warehousing costs, intern al transfer costs, and the
other costs of your distribution network in th e cost of revenues line item.  With the

Mr. Jerry L. Peters
March 19, 2008
Page 3 of 4
exception of warehousing costs, if you curren tly exclude a portion of these costs from
cost of goods sold, please disclose:
• in a footnote the line items that thes e 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 goods sold  and others like you exclude a portion of them from
gross margin, including them instead in a line item, such as operating expenses.

Recoverable Rail Line Costs, page F-11

6. You recorded an asset of $3.5 million at November 30, 2006 and November 30, 2007 for recoverable rail line costs.  Please he lp us understand how you determined it was
appropriate to capitalize the $3.5 million paid for renovation costs instead of
recording as an expense in the period paid.  Your di sclosures indicate that the
provision for reimbursement is contingent  on sufficient rail cars being placed on the
rail line.  Please tell us whether the terms of this contingency have been met as well as whether you have been reimbursed for any of  these recoverable rail  line costs.  If
so, tell us the amounts which have been reimbursed.  For any amounts not reimbursed, tell us when you expect to be reimbursed.

Revenue Recognition, page F-12

7. On page F-23 you disclose that you have ex ecuted a lease contract for 100 rail cars
for a ten-year period for $68,700 per month for the Shenandoah facility.  You use
these rail cars to ship dried distiller grains to customers.  For the dried distiller grains
for which you are responsible for shippi ng to customers, please expand your
disclosure to address at which point you record revenue s.  Please address how you
determined the criteria included in the first sentence of your revenue recognition
policy have been satisfied at this time.

8. Please expand your revenue recognition pol icy to address how you recognize revenue
related to grain merchandising and storage.

Note 9.  Earnings Per Share, page F-21

9. For each period presented, please disclose sepa rately for each type of security the
number of shares that were not included in diluted EPS because they were antidilutive.

*    *    *    *

Mr. Jerry L. Peters
March 19, 2008
Page 4 of 4
  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
information.  Detailed letters greatly facilitate our review.  Please file your supplemental
response on EDGAR as a correspondence file .  Please understand that we may have
additional comments after reviewin g your responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating 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 advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance 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 Nudrat
Salik, Staff Accountant, at ( 202) 551-3692 or, in her absence,  to the undersigned at (202)
551-3769.

       S i n c e r e l y ,

       R u f u s  D e c k e r
       Accounting Branch Chief