SEC Comment Letter for Clean Energy Fuels Corp. (CLNE) (CIK 0001368265) (CLNE) — Oct 22, 2015
Clean Energy Fuels Corp. (CLNE) (CIK 0001368265)
Date: Oct. 22, 2015 · CIK: 0001368265 · Accession: 0000000000-15-050962
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 October 22, 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 October 14, 2015 File No. 001 -33480
Dear Mr. Littlefair:
We have reviewed your October 14 , 2015 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 this comment 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 comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comme nts in our October 6 , 2015 letter .
Form 10 -K for the Fiscal Year Ended December 31, 2014
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 1 and y our conclusion that change s in the average price per fuel type did not materially impact revenue fluctuations between periods. You state in your response that the impact of the change in average price for LNG between 2014 as compared to 2013 and 2013 as c ompared to 2012 was $9.8 million and $5.9 million, respectively. Based on statement of operations information on page 63, this amounts to approximately 13% and 32% of the change in revenues for 2014 as compared
Andrew J. Littlefair Clean Energy Fuels Corp. October 22, 2015 Page 2
to 2013 and 2013 as compared to 2012, respec tively. Please tell us why you do not believe this LNG price impact represents a material change in revenues and why such information should not be disclosed as a supplement to your total volume discussion .
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. Please contact me at (202) 551 -3720 with any other questions.
Sincerely,
/s/ Lisa M. Kohl for
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Mail Stop 3561 October 22, 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 October 14, 2015 File No. 001 -33480 Dear Mr. Littlefair: We have reviewed your October 14 , 2015 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 this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comme nts in our October 6 , 2015 letter . Form 10 -K for the Fiscal Year Ended December 31, 2014 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 1 and y our conclusion that change s in the average price per fuel type did not materially impact revenue fluctuations between periods. You state in your response that the impact of the change in average price for LNG between 2014 as compared to 2013 and 2013 as c ompared to 2012 was $9.8 million and $5.9 million, respectively. Based on statement of operations information on page 63, this amounts to approximately 13% and 32% of the change in revenues for 2014 as compared Andrew J. Littlefair Clean Energy Fuels Corp. October 22, 2015 Page 2 to 2013 and 2013 as compared to 2012, respec tively. Please tell us why you do not believe this LNG price impact represents a material change in revenues and why such information should not be disclosed as a supplement to your total volume discussion . 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. Please contact me at (202) 551 -3720 with any other questions. Sincerely, /s/ Lisa M. Kohl for Mara Ransom Assistant Director Office of Consumer Products