TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo September 13, 2022 G. Patrich Simpkins Chief Financial Officer Green Plains Inc. 1811 Aksarben Drive Omaha, Nebraska 68106 Re: Green Plains Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 18, 2022 File No: 001-32924 Dear Mr. Simpkins: We have reviewed your August 5, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the fiscal year ended December 31, 2021 Results of Operations Ethanol Production Segment, page 45 1. We acknowledge your proposed disclosure revisions provided in response to comment 1 addressing key factors driving period-to-period changes in reported revenues. However, your response does not address key factors driving period-to-period changes in your operating income and associated margins. In this regard, your disclosure on page 45 indicates that operating income in your Ethanol production segment increased $101.6 million in 2021 compared with 2020 primarily due to "improved margins" offset by the write-off of goodwill during fiscal year 2020. Please provide us with proposed disclosure to be included in future filings that quantifies and explains the key factors driving period- to-period changes in your margins and their associated impact on operating income. As part of your proposed disclosure revisions, address the impact on your margins of commodity price risk management activities for each period presented, including the G. Patrich Simpkins Green Plains Inc. September 13, 2022 Page 2 impact of successful risk management activities that lock-in margins and unsuccessful risk management activities that result in mismatches. You may contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426, if you have questions. FirstName LastNameG. Patrich Simpkins Sincerely, Comapany NameGreen Plains Inc. Division of Corporation Finance September 13, 2022 Page 2 Office of Life Sciences FirstName LastName