August 1, 2025

Robert Vreeland
Chief Financial 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, 2024
           Filed February 24, 2025
           File No. 001-33480
Dear Robert Vreeland:

       We have reviewed your filing and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Business
Market Opportunity, page 7

1.     We note your disclosures on page 8 regarding the two arrangements
entered into
       during 2021 covering ADG RNG projects, including the "TotalEnergies JV
       Agreement" and "bp JV Agreement," for which you specify the number of
       projects and status, indicating one project under the first arrangement
is in operation
       (which you refer to as "DR JV"), and five of six projects under the
second
       arrangement are in operation, also having estimates of annual
production.

       However, within the MD&A Overview on page 35 you indicate that your
supply of
       RNG is acquired either from third parties or through the TotalEnergies
JV, with no
       mention of the bp JV, and under Key Developments on page 37, you
indicate the DR
       JV began producing RNG in the first quarter of 2023, while the Drumgoon
Dairy
       project under the bp JV was placed into service in the fourth quarter of
2023, though
       having no details regarding the other four projects under the bp JV that
are in
       operation, according to the disclosures referenced above.
 August 1, 2025
Page 2


       We also note that while your estimates of annual production for these
projects have
       decreased about 27% there appears to be no discussion of the reasons.
For example,
       you previously indicated the TotalEnergies JV project was expected to
produce up to
       1.1 million GGEs of RNG annually, and that six projects under the bp JV
Agreement
       were expected to produce up to 11.2 million GGEs of RNG annually; you
now
       indicate the figures are 0.8 million and 8.2 million GGEs, respectively.

       Please expand your disclosures to clarify the status of all projects
under these
       arrangements and to include (i) details on the actual levels of
production for each
       period, (ii) clarification regarding the extent to which your RNG
requirements are
       being satisfied by these projects or other facilities that you own,
(iii) your expectations
       regarding the production profiles and capabilities, and (iv) the reasons
for any changes
       in those expectations, or delays in completing projects or commencing
production.

       Please provide comparable details for the 100% owned ADG RNG projects
for which
       you estimate RNG production of 3.6 million GGEs per year.

Properties, page 32

2.     Please expand your disclosure regarding the Pickens Plant, which you
indicate was
       "offline for maintenance and repairs" for the last two years (with zero
LNG
       production for both 2023 and 2024), to clarify the status of this
facility, the nature of
       the issues that have inhibited its use, and your plans to remedy those
issues along with
       the expected costs and timeframe. Please disclose the reasons that you
have been
       unable to make the necessary repairs during the last two years.

Management's Discussion and Analysis
Liquidity and Capital Resources, page 49

3.     We note your disclosure stating that your business plans call for $30
million in capital
       expenditures during 2025, although also stating that you expect to be
"deploying"
       $104.0 million to develop ADG RNG production facilities during the year.

       Please expand your disclosures to clarify the distinction being made
between capital
       expenditures and amounts required for the ADG RNG facilities, and
explain how the
       estimated amount relates to your expectations for additional amounts
that may be
       required under the joint venture arrangements mentioned on pages 8 and 9
(including
       but not limited to the three company projects and any projects with Maas
JDA), and
       considering the amounts for ADG RNG production facilities in your table
on 51.

       Please also clarify your expectations for additional projects under the
TotalEnergies
       JV Agreement, considering your disclosure indicating the joint venture
contemplates
       investing up to $400.0 million in production projects, and the timeframe
in which
       these would be undertaken or become known.
 August 1, 2025
Page 3

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact John Cannarella at 202-551-3337 or Karl Hiller at
202-551-3686 if you
have questions regarding comments on the financial statements and related
matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Energy &
Transportation