July 15, 2005



Mr. James A. Seurer
Chief Financial Officer
South Dakota Soybean Processors, LLC
100 Caspian Avenue, P.O. Box 500
Volga, South Dakota 57071


	Re:	South Dakota Soybean Processor, LLC
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed April 15, 2005
      Response Letter Dated June 21, 2005
      File No. 0-50253
      Post Effective Amendment to Registration Statement on Form
S-1
      Filed June 9, 2005
      File No.  333-114508

Dear Mr. James Seurer:

      We have reviewed your response letter and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents. 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.


Form 10-K for the Fiscal Year Ended December 31, 2004

Management`s Discussion and Analysis

Results of Operations, page 12

1. We note your response to our prior comment three conveying your
belief that your soybean meal and soybean oil refining do not
constitute reportable segments. However we were unable to locate
the
balance of your response in which we had requested you to provide
us
with the financial reports your CODM reviews.  Please provide us
with
the balance of your response.

Report of Independent Registered Public Accounting Firm, page F-2

2. We note your response to our prior comment two indicating that
Eide Bailly had provided services relating to the preparation of
your
2003 consolidated financial statements. We note that you believe
an
exemption applied under Section 602.02.c, however, that section
was
revised early in 2003 and the timing of your fact pattern appears
to
be outside the transition period provided in the rule.
Accordingly,
it appears that your auditor, Eide Bailly, was not independent and
their audit report issued on your financial statements for the
year
ended December 31, 2003 does not comply with the requirements of
Article 2 of Regulation S-X.  Please amend your filing to provide
audited financial statements for the year ended December 31, 2003
that are audited by an independent accountant as required by
Article
2 of Regulation S-X.  Please contact us to further discuss the
audit
of the financial statements for the period ended December 31, 2002
included in this filing. Please refer to Final Rule 33-8183
Strengthening the Commission`s Requirements Regarding Auditor
Independence at http://www.sec.gov/rules/final/33-8183.htm.


Registration Statement on Form S-1

3. Given the above information in comment 2, we call your
attention
to your S-1 registration statement that went effective February
14,
2005 containing an audit report that did not meet the requirements
of
Article 2 of Regulation S-X.  Please advise us of any sales that
have
taken place since the effective date of the S-1 and what steps you
intend to take in this regard.


Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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.


You may contact Jon Duersch at (202) 551-3719, if you have
questions
regarding comments on the financial statements and related
matters.
Please contact Jill Davis, Branch Chief, at (202) 551-3683, in his
absence.  Direct questions on other disclosure issues to Carrie
Darling at (202) 551-3724 or, in her absence, to the undersigned,
at
(202) 551-3740.  Direct any correspondence to us at the following
ZIP
Code:  20549.


								Sincerely,



								H.  Roger Schwall
								Assistant Director


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Mr. James Seurer
South Dakota Processors LLP
July 15, 2005
page 1




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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010