SecProbe.io

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Mail Stop 6010

October 14, 2005

Robert E. Bettger
Director
Advanced BioEnergy, LLC
910 9th Street
Fairmont, Nebraska 68354

Re:	Advanced BioEnergy, LLC
	Amendment No. 2 to Registration Statement on Form SB-2
      Filed September 30, 2005
	Registration No. 333-125335

Dear Mr. Bettger:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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 may 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.

Estimated Use of Proceeds, page 35

1. Please explain what you mean by DDGS.

Certain Relationships and Related Transactions, page 69

2. We note your response to our prior comment 15.  With regard to
the
units issued and sold to Messrs. Stephenson, Holmes and Porter,
who
have been directors since your inception, please tell us how those
directors were not related parties at the time their respective
units
were issued.  For example, if they were not related parties at the
time of those sales, please tell us who authorized and approved
such
sales.  For the issuances of the shares to your other directors,
please tell us what understandings you had with such directors at
the
time your units were sold to those directors and whether those
directors would be considered related parties at the time of such
sales by virtue of their being a "nominee for election as a
director"
as contemplated by Item 404(a)(2) of Regulation S-B.

3. Please disclose the terms of your arrangements with Timberwood
Bank.

Plan of Distribution, page 70

4. Please expand your response to the third bullet point in
comment
18 to clarify how you would use the representations as a defense
in
an action brought under the federal securities laws.  Also clarify
how your assertion of such a defense would be appropriate given
section 14 of the Securities Act.

5. Please expand your response to prior comment 21 to provide us a
substantive legal and factual analysis of how each person who is
distribution participant satisfies the exemption given Rule 3a4-
1(a)(4)(ii)(C).

Summary of Promotional and Sales Material, page 76

6. We note your responses to prior comments 24 and 25.  Please
provide us with (1) screenshots of all Internet pages to be used
in
connection with the distribution and (2) copies of the materials
that
you have mentioned in those responses.  Also provide us copies of
all
advertisements you intend to use.  We may have further comment
upon
our review.

Loss of Membership Rights, page 77

7. In the second paragraph you state that membership rights can be
terminated by transfer of units.  In the third paragraph you state
that investors whose membership rights have been terminated
continue
to share in profits, losses and distributions.  Please clarify why
an
investor who has transferred its rights is still entitled to
continue
to share in profits, losses and distributions.

8. Please clarify how you may admit a "substitute member."  May
you
admit such a substitute without the original member`s consent?

Part II of Registration Statement

9. Please file the Phase I and Phase II Engineering Services
Agreement that you have entered into with Fagen, Inc. as an
exhibit
to your registration statement.

Exhibit 4.2

10. We note your response to prior comment 35.  However, we
continue
to believe that it is inappropriate to require investors to
certify
that they have read the prospectus or otherwise taken action which
implies that they have waived rights under the federal securities
laws.  Please revise the subscription agreement accordingly.

Exhibit 8.1

11. Please file updated exhibits 5.1 and 8.1 without blanks in the
text.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Patrick Enunwaonye at (202) 551-3645 or Gary
Todd, Review Accountant, at (202) 551-3605, if you have questions
regarding our comments on the financial statements and related
matters.  Please contact Tim Buchmiller at (202) 551-3635 or me at
(202) 551-3617 with any other questions.

      Sincerely,

							Russell Mancuso
							Branch Chief

cc:	William E. Hanigan, Esq.
	Miranda L. Hughes, Esq.
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Robert E. Bettger
Advanced BioEnergy, LLC
October 14, 2005
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