SecProbe.io

September 15, 2011
 Via E-mail

Mr. Jerry L. Peters Chief Financial Officer Green Plains Renewable Energy, Inc. 9420 Underwood Avenue, Suite 100 Omaha, NE  68114
RE: Green Plains Renewable Energy, Inc.
Form 10-K for Fiscal Year  ended December 31, 2010
Filed March 4, 2011
  Form 10-Q for the Fiscal Quarter ended June 30, 2011   Filed August 5, 2011   File No. 1-32924

Dear Mr. Peters:
 We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for the Fiscal Year Ended December 31, 2010

 General

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

Mr. Jerry L. Peters Green Plains Renewable Energy, Inc. September 15, 2011 Page 2

 Item 7 – Management’s Discussion and Analysis…, page 39

 Impairment of Long-Lived Assets and Goodwill, page 42

 2. To the extent that any of your reporting units  have estimated fair values that are not
substantially in excess of the carrying valu e and to the extent that goodwill for these
reporting units, in the aggregate or individually, if impaired, c ould materially impact your
operating results, please provide the following disc losures for each of these reporting units in
future filings:
 Identify the reporting unit;
 The percentage by which fair value exceeds the carrying value as of the most-recent step-
one test;
 The amount of goodwill;
 A description of the assumptions that  drive the estimated fair value;
 A discussion of the uncertainty associated w ith the key assumptions.  For example, to the
extent that you have included assumptions in your discounted cas h flow model that
materially deviates from your historical re sults, please include a discussion of these
assumptions; and
 A discussion of any potential events and/or circumstances that could have a negative
effect to the estimated fair value.
If you have determined that the estimated fair value substantially exceeds the carrying value for all of your reporting units, please disclose this determination.  Pl ease also provide the
above disclosures, as ap plicable, for any long-lived assets or asset groups for which you have
determined that fair value is not substantially in excess of the carrying value and to the extent
that the asset amounts, in the aggregate or  individually, could materially impact your
operating results.  Please refer to Item 303 of  Regulation S-K and Sections 216 and 501.14 of
the SEC’s Codification of Financia l Reporting Policies for guidance.

Item 15 – Exhibits, Financial Statement Schedules, page 63

 Note 7 – Segment Information, page F-17

 3. Please revise the table on page F-18 to present for each segment revenues from external
customers as well as intersegment revenues as required by ASC 280-10 -50-22(a) and (b).
Refer to the example set forth in ASC 280-10-55-48.
 Note 11 – Long-Term Debt, page F-23

 4. You disclose here and on pages 18 and 19 th at you obtained waiver s related to your non-
compliance with various debt covenants.  Pleas e disclose when each waiver was obtained and
the facts and circumstances that required it.  Pl ease also disclose the specific debt covenants
that you were not in compliance with including the actual ratios/amounts as compared to the
required ratios/amounts, along with any revisions  to the required ratios/amounts that occurred
for current or future periods as a result of disc ussions with the lenders.  Please also disclose

Mr. Jerry L. Peters Green Plains Renewable Energy, Inc. September 15, 2011 Page 3

 the duration of each waiver.  Pl ease disclose whether each of your  various debt arrangements
have cross default provisions.  Please disclose  whether you believe that you will be able to
comply with each covenant that was violated fo r the next twelve months without the need to
obtain additional waivers.  Please also explain how additional futu re violations of these debt
covenants would impact your liquidity.
 5. For any material debt covenant s that required a waiver or fo r which it is reasonably likely
that either (a) you will not be able to meet  or (b) could limit your ability to undertake
additional debt or equity fina ncing, please also disclose the specific computations used to
arrive at the actual ratios/amounts with co rresponding reconciliations to U.S. GAAP
amounts. See Sections I.D and IV.C of th e SEC Interpretive Release No. 33-8350 and
Compliance and Disclosures Interpretation 102.0 9 which is available on our website at
http://www.sec.gov/divisions/corpf in/guidance/nongaapinterp.htm.
 Note 15 – Commitments and Contingencies, page F-36

 Operating Leases, page F-36

 6. Please disclose how you account for (a) step re nt provisions and escalation clauses and (b)
capital improvement funding and other lease concessions, which may be present in your
leases.  Lease payments that depend on an exis ting index or rate, such as the consumer price
index or the prime interest rate , should also be included in your minimum lease payments.  If,
as we assume, they are taken into account in computing your minimum lease payments and
the minimum lease payments are recognized on a straight-line basis over the minimum lease
term, the note should so state.  If our assu mption is incorrect, please tell us how your
accounting complies with ASC 840.
 Form 10-Q for the Fiscal Quarter Ended June 30, 2011

 7. Please address the above comments in your in terim filings as well, as applicable.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 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

Mr. Jerry L. Peters Green Plains Renewable Energy, Inc. September 15, 2011 Page 4

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Jeffrey Gor don, Staff Accountant, at (202)  551-3866 or, in his absence,
the undersigned at (202) 551- 3769 if you have questions regarding these comments.
      Sincerely,   /s/ Rufus Decker       Rufus Decker  Accounting Branch Chief  cc: Via E-mail

 Glen Kampschneider  Vice President & Corporate Controller