SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                              BLACKBURN & STOLL, LC
                                Attorneys at Law
                         77 West Second South, Suite 400
                           Salt Lake City, Utah 84101
                            Telephone (801) 521-7900
                               Fax (801) 521-7965
                                                                Eric L. Robinson
                                                           Direct (801) 578-3553

                                  March 4, 2005

Ms. Pamela A. Long
Assistant Director
U.S. Securities and Exchange Commission
Mail Stop 0510
Washington, D.C. 20549-0510

      Re:    Green Plains Renewable Energy, Inc.
             Form S-1/A, Filed February 28, 2005
             File No. 333-121321

Dear Ms. Long:

         This letter is submitted on behalf of Green Plains Renewable Energy,
Inc. (the "Company") in response to the comments of the staff of the Division of
Corporation Finance of the Securities and Exchange Commission ("SEC") with
respect to the Company's Registration Statement of Form S-1/A that was filed on
February 28, 2005 (the "Registration Statement"). We appreciate the careful
review and the useful comments provided by the staff. The accompanying amendment
to the Registration Statement has been revised in response to the staff's
comment and has been updated to reflect developments in the Company's business.

         The following sets forth the SEC staff's comments as reflected in the
staff's letter dated March 3, 2005, and the corresponding responses of the
Company to those comments that require responses. Factual information was
provided to us by the Company without independent verification by us. SEC staff
comments are provided in italicized print and in numerical sequence in this
letter, and the corresponding responses of the Company, where required, are
shown in indented text.

Business, page 31
Our Primary Competition, page 40

         1. We note your new risk factor on page 16. Please expand your
disclosure in this section to discuss competition from foreign producers of
ethanol.

         The risk factor and the discussion in the business section has been
         revised to respond to this comment. See pages 16 and 39.

<PAGE>
Ms. Long
March 4, 2005
Page 2

Report of Independent Registered Public Accountants, page F-1

         2. We have read your response to our comment 8. Your response indicates
that your auditor's report has been revised to indicate that they conducted
their audit in accordance with "the standards of the Public Company Accounting
Oversight Board (United States)" rather than in accordance with "auditing
standards of the Public Company Accounting Oversight Board (United States)."
However, it does not appear that this change bas been made in the auditor's
report included in this filing on Form S-1/A. Please obtain and include from
your auditors a revised opinion. Refer to PCAOB Standard No. 1, Exhibit 2

         The auditor's report has been revised which removed the word
         "auditing". The sentence indicates "We conducted our audit in
         accordance with the standards of the Public Company Accounting
         Oversight Board (United States)."

         3. We have read your response to our comment 9. While the revised audit
report obtained from your auditors has dual dated the effects of the
restatements as described in Note 5, it does not reference the restatement to
record stock-based compensation, the reclassification of the deposit in your
statement of cash flows, and the footnote that discusses each in greater detail
within the audit report itself. Please obtain and include in your amended
filing, an updated opinion from your auditors, as well as an updated consent.

         The auditor's report has been revised to include the reference to the
         restatement for the stock-based compensation and the reclassification
         of the deposit in the statement of cash flows. Additionally, we have
         included footnote 5 that discusses each of these in greater detail in
         accordance with APB 20 paragraph 37.

Statement of Cash Flows, page F-5

         4. Your statement of cash flows does not present the $37,500 adjustment
relating to stock based compensation required to reconcile the net loss to the
net cash used by operating activities. Please revise to include this. Refer to
paragraphs 28 and 29 of SPAS 95.

         The statement of cash flows was improperly formatted which did not
         clearly present the $37,500 adjustment relating to stock-based
         compensation. We have revised the formatting to properly reflect the
         adjustment.

<PAGE>
Ms. Long
March 4, 2005
Page 3

Exhibit 23.1, Consent of L.L. Bradford & Company, LLC

         5. We have read your response to our comment 9. Your updated consent
from your auditors references their consent in the registration statement filed
on Form S-1. Please obtain and include an updated consent from your auditors
which references their consent to your registration statement filed on Form
S-1/A.

         We have obtained and included an updated consent from our auditors
         which references their consent to our registration statement filed on
         Form S-1/A.

         Please contact the undersigned at (801) 578-3553 with any questions or
comments regarding this letter. Thank you for your assistance in this matter.

                                                     Very truly yours,

                                                     BLACKBURN & STOLL, LC

                                                     /s/ Eric L. Robinson

                                                     Eric L. Robinson

cc: Mr. Barry Ellsworth
</TEXT>
</DOCUMENT>