SecProbe.io

Mail Stop 3561

October 6, 2015

Andrew J. Littlefair
President and Chief Executive Officer
Clean Energy Fuels Corp.
4675 MacArthur Court, Suite 800
Newport Beach, CA 92660

Re: Clean Energy Fuels Corp.
Form 10-K for the Fiscal Year Ended December 31, 2014
Response Dated September 18, 2015
File No. 001 -33480

Dear Mr. Littlefair:

We have reviewed  your September 18, 2015 response to our comment  letter  and have the
following comment s.  In some of our comments , we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our September
3, 2015 letter .

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Key Operating Data, page 36

1. We note your response to comment 4.  You state that the sources of GGE v olumes have
varying financial  impacts and the effective price per GGE provides investors with insight
into a significant portion of your revenue.  We have the following comments as it relates
to your use of this metric in your results of operations discuss ion:

 Please supplement your total GGE volume figure by separately quantifying within
results of operations the portion related to O&M stations or tell us why such
information would not be useful to investors.  We note that GGE’s delivered at O&M

Andrew J. Littlefair
Clean Energy Fuels Corp.
October 6, 2015
Page 2

 station s represent over half of total volumes for the annual periods presented and that
you earn a per -gallon fee on such volumes.  Also, quantify for us and disclose the
related O&M revenues for each period presented as well as the impact on your
revenues of cha nges, if any, in the price of those services between periods.  Refer to
Item 303(A)(3)(iii) of Regulation S -K.

 Clearly disclose how you calculate the effective price and cost per gallon figures
presented within your results of operations.  In doing so, cl arify that such figures
include volumes for stations that you do not own but provide O&M services and
receive a per -gallon fee.

 You separately explain the changes in GGE delivered by CNG, LNG and RNG in
your discussion of changes in revenues, such as on p age 48.  Please tell us whether
the difference in price for each of these fuel types materially impacted reported
revenues for the periods presented and, if so, tell us and disclose the impact.

You may contact Jarrett Torno, Staff Accountant, at (202) 551-3703  or Andrew Blume,
Staff Accountant, at (202) 551-3254  if you have questions regarding comments on the financial
statements and related matters.

Sincerely,

/s/ Lisa M. Kohl for

Mara Ransom
Assistant Director
Office of Consumer Products