Dear Chris Duke and the…

Dear Chris Duke and the OMAFRA Team,

Clean Energy Fuels is pleased to participate in the discussion on the level of interest in production and use of Renewable Natural Gas (RNG) as transportation fuel. We feel our background and 20 + years of experience makes Clean Energy a subject matter expert on renewable natural gas as a transportation fuel.

Background on Clean Energy: Clean Energy Fuels was founded in 1996 with stable leadership from our founders, T. Boone Pickens and Andrew J. Littlefair and is the largest provider of natural gas for transportation in North America, both in number of stations and liters sold per year. As a vertically integrated company, CE designs, builds, operates and maintains CNG, Liquefied Natural Gas (LNG), Renewable Natural Gas (RNG) and Liquid to Compressed Natural Gas (LCNG) fueling stations. CE currently fuels more than 45,000 NGVs daily at over 570 stations throughout North America.

With over 970 employees worldwide, CE is headquartered in Newport Beach, CA and five other regional offices located in Vancouver, BC; Concord, NH; and Dallas, TX. In Canada, we have over 200 employees here and are active in every province, including Ontario, except Newfoundland. Clean Energy is already buying and marketing RNG produced in Canada and selling it to transit, refuse and trucking fleets and looking for more RNG and customers. For more information on Clean Energy, please go to: https://www.cleanenergyfuels.com .

The RNG we sell for vehicle fuel, which is delivered in the form of CNG or LNG is distributed under the name Redeem™. The amount of Redeem vehicle fuel we delivered increased from 20.2 million GGEs in 2014 to 58.6 million GGEs in 2016, a 190.1% increase. We believe this demand for Redeem™ is largely attributable to the lower greenhouse gas emissions that it produces relative to gasoline and diesel.

For more information on Clean Energy’s Renewable Natural Gas for Transportation product offerings, please go to: http://redeem.cleanenergyfuels.com .

The Team at Clean Energy is ready and willing to provide any additional information and meet with the OMAFRA Team in person to discuss ways that we can support the adoption of RNG as a transportation fuel in Ontario.

Please find below our responses to the 10 questions outlined in the “Proposed Agrifood Renewable Natural Gas for Transportation Demonstration Program” discussion paper:

___________________________________________________________________________________________________ ___________________________________________________ 1.What are the best opportunities for successful agrifood RNG for transportation projects? Which businesses or organizations are best prepared to successfully deploy RNG anaerobic digesters and natural gas fuelled fleets? What other business partners and business relationships will need to be in place for projects to succeed?

a.There are RNG projects that are able to be developed now across landfills, WWTPs, agricultural operations and other uses of anaerobic digesters, the key driver for these will be financial incentive such as environmental commodity that is generated from the use of RNG as a vehicle fuel.

b.The highest and best use for RNG is vehicle transport in a market that must be unfettered by any utility trying to control any part of the business other than moving the molecules through their “natural monopoly” pipelines – more specifically, up stream of the inlet or downstream of their outlet/meter. With respect to vehicle types – the best opportunities would be for diesel-powered transit buses, refuse and heavy duty truck applications. We feel that displacing diesel only (as opposed to gasoline) would have the greatest GHG reduction impact.

c.A relationship with a full-service provider in the natural gas business with a vast, North American fueling network like Clean Energy would lead to a fast and seamless implementation of RNG for transportation projects in Ontario.

d.Another crucial relationship would be with the Cummins-Westport. CWI is the manufacturer of the only fuel technology platform that meets all the commercial feasibility and logistics tests to immediately begin this transformation: near zero emission heavy duty NGVs fueled by increasing volumes of ultra low GHG renewable natural gas (RNG). For more information on Cummins-Westport, please go here: http://www.cumminswestport.com/

2.What are the key financial opportunities that will help projects to succeed?

a.The key driver that will enable RNG projects to succeed is an incentive for its use as a vehicle fuel as well, an incentive for fleets to acquire natural gas-powered vehicles as well as an incentive for the construction of a natural gas fueling network.

b.Under “Action Area: Transportation” section 4.1 (page 64) of the Climate Change Action Plan announced the creation of the $170 million Green Commercial Vehicle program back on June 8, 2016 – yet to date nothing has been announced with respect to funding eligibility criteria and timing. This program needs to move ahead immediately.

c. Under “Action Area: Transportation” section 4.2 (page 64) of the Climate Change Action Plan announced the creation of a $100 million fund to “Build a network of low-emission fuelling stations” back on June 8, 2016 – yet to date nothing has been announced with respect to funding eligibility criteria and timing. This program needs to move ahead immediately.

d.NRCAN has awarded $5 million to Clean Energy, Union Gas and Enbridge to build natural gas fueling stations in Ontario under the condition that they be built and operational by March 31, 2018. WITHOUT FUNDING OF THE GREEN COMMERCIAL VEHICLE PROGRAM, THESE STATIONS WILL NOT BE BUILT DUE TO THE ABSENCE OF FLEET CUSTOMERS.

3.At what scale would a project have to be deployed to be successful? How much RNG production? How many vehicles?

a.RNG production can be successful at many different levels- small scale projects matched to on-site demand can work, as can larger scale projects that are injected into an interstate pipeline and delivered to multiple fueling locations. We have seen successful projects range from 50 MMBtus/day to 6,000 MMBtus/day.

4.Are businesses and organizations ready to develop and deploy RNG for transportation projects? Are there gaps in the supply chain? What would improve companies’ readiness?

a.Yes, there are many potential biogas sources that can be developed into RNG projects producing pipeline-quality natural gas. Owners of the facilities that produce biogas, biogas rights owners, and project developers are all able to coordinate and develop successful projects pending a marketplace that will cover the cost of production and incentivize the use of their RNG over conventional natural gas.

b.With respect to gaps in the supply chain – much of the Ontario (Canadian) supply is sold outside of Canada to the US where there are (LCFS and RIN’s) credits that result in a higher sale price to the Ontario-based producer than if the fuel was sold in Ontario.

c.Ontario needs to create their own Low Carbon Fuel Standard for diesel and not just for gasoline (which is currently under review).

d.Under “Action Area: Buildings and Homes”, section 6.1 (page 68) of the Climate Change Action Plan - $100 million has been allocated to “Establish low-carbon content for natural gas”…in…transportation…sectors”. We suggest using $20 million of this $100 million to support a Low Carbon Fuel Standard credit for diesel.

5.What barriers to do you foresee to developing a successful project? How can these barriers be overcome?

a.The most important tool for success is developing a low carbon fuel standard or renewable fuel standard that will incentivize each MMBtu of RNG production and create ongoing demand for the RNG product in Ontario. The federal and local government should create programs modeled on similar program that have driven RNG use in the US, that allow for the development of long-term production of RNG.

b.For more information on the LCFS in California, go to https://www.arb.ca.gov/fuels/lcfs/lcfs.htm

c.Under “Action Area: Buildings and Homes”, section 6.1 (page 68) of the Climate Change Action Plan - $100 million has been allocated to “Establish low-carbon content for natural gas”…in…transportation…sectors”. We suggest using $20 million of this $100 million to support a Low Carbon Fuel Standard credit for diesel.

6.How long would it take to deploy an RNG for transportation project from conception to successful operation?

a.Many factors will dictate how long a project will take to reach commercial operation, such as permitting, gas rights, engineering, and construction. Each project is unique but a timeline of 18-24 months can be reasonable in many cases for a large-scale RNG project with financing in place.

7.Describe the types of government support needed to successfully deploy RNG for transportation projects.

a.Under “Action Area: Transportation” section 4.1 (page 64) of the Climate Change Action Plan announced the creation of the $170 million Green Commercial Vehicle program back on June 8, 2016 – yet to date nothing has been announced with respect to funding eligibility criteria and timing. This program needs to move ahead immediately.

b. Under “Action Area: Transportation” section 4.2 (page 64) of the Climate Change Action Plan announced the creation of a $100 million fund to “Build a network of low-emission fuelling stations” back on June 8, 2016 – yet to date nothing has been announced with respect to funding eligibility criteria and timing. This program needs to move ahead immediately.

c.The most important tool for success is developing a low carbon fuel standard or renewable fuel standard that will incentivize each MMBtu of RNG production and create ongoing demand for the RNG product in Ontario. The federal and local government should create programs modeled on similar program that have driven RNG use in the US, that allow for the development of long-term production of RNG.

d.For more information on the LCFS in California, go to https://www.arb.ca.gov/fuels/lcfs/lcfs.htm

e.Under “Action Area: Buildings and Homes”, section 6.1 (page 68) of the Climate Change Action Plan - $100 million has been allocated to “Establish low-carbon content for natural gas”…in…transportation…sectors”. We suggest using $20 million of this $100 million to support a Low Carbon Fuel Standard credit for diesel.

8.What are some criteria or project attributes that should be considered or prioritized for a project to be supported through this program?

a.Commitment to long-term RNG production, use of the fuel as a transportation fuel, developing projects that utilize existing biogas and/or capture vented methane such as agricultural operations. Creating greater incentives for these fugitive emissions will create the greatest benefit in terms of GHG emissions reductions.

b.Under “Action Area: Transportation” section 4.1 (page 64) of the Climate Change Action Plan announced the creation of the $170 million Green Commercial Vehicle program back on June 8, 2016 – yet to date nothing has been announced with respect to funding eligibility criteria and timing. This program needs to move ahead immediately.

9.What should be included in the program to ensure broader uptake of RNG for transportation after the program is completed?

a.There is a vast natural gas fueling infrastructure in the US. For Ontario-based customers that wish to travel outside of Ontario, it would be helpful if they could know where to buy CNG in the US for example. For more information, please go here: http://www.cngnow.com/stations/Pages/information.aspx

b.Benefits of Natural Gas Fuel i.Domestic and Plentiful Supply. Technological advances in natural gas drilling and production, including the widespread deployment of horizontal drilling techniques and the use of hydraulic fracturing, have unlocked vast natural gas reserves. The United States produces the highest volume of natural gas in the world, with proven, abundant and growing reserves of natural gas.

ii.Less Expensive. Due to the abundance of natural gas, the cost of natural gas in the United States is less than the cost of crude oil, on an energy equivalent basis. Based on projections from the U.S. Energy Information Administration, we believe that natural gas will remain cheaper than gasoline and diesel for the foreseeable future. In addition, because the price of the natural gas commodity makes up a smaller portion of the cost of a GGE of CNG or LNG relative to the commodity portion of the cost of a GGE of diesel or gasoline, the price of a GGE of CNG or LNG is less sensitive to increases in the underlying commodity cost.

iii.Cleaner. Natural gas contains less carbon than any other fossil fuel and thus produces fewer carbon dioxide emissions when burned. The California Air Resources Board ("CARB") has concluded that a natural gas vehicle emits fewer greenhouse gas emissions than a comparable gasoline or diesel fueled vehicle on a well-to-wheel basis. Additionally, a study from Argonne National Laboratory, a research laboratory operated by the University of Chicago for the U.S. Department of Energy, indicates that natural gas vehicles produce at least 13% to 21% fewer greenhouse gas emissions than comparable gasoline and diesel fueled vehicles. For natural gas vehicles that run on RNG, we estimate, based on CARB data, that the greenhouse gas emissions produced are from 50% to 125% less than comparable gasoline and diesel fueled vehicles, depending on the source of biogas. We believe the RNG we sell for use as a vehicle fuel, which is distributed under the brand name Redeem™, is the first commercially available RNG vehicle fuel made from organic waste.

iv.Safer. As reported by NGV America, CNG and LNG are relatively safer than gasoline and diesel because they dissipate into the air when spilled or in the event of a vehicle accident. When released, CNG and LNG are also less combustible than gasoline or diesel because they ignite only at relatively high temperatures. The fuel tanks and systems used in natural gas vehicles are subjected to a number of federally required safety tests, such as fire, environmental hazard, burst pressure and crash testing, according to the U.S. Department of Transportation National Highway Traffic Safety Administration. Additionally, CNG and LNG are stored in above-ground tanks and therefore will not contaminate soil or groundwater in the event of a spill or leak.

c.Near Zero emission technology is commercially available today. For more information please go to: http://www.cumminswestport.com/models/isl-g-near-zero

d.Once the $170 million Green Commercial Vehicle Program details are announced, they should be publicised by provincial media coverage.

e.Working in partnership with Clean Energy, Union Gas and Enbridge, we will announce the construction and anticipated opening dates of our stations in Ontario – but only after the details of the Green Commercial Vehicle Program are publically announced.

10.Please comment on any other requirements or considerations for the Agrifood RNG for Transportation Demonstration program.

a.The success of California’s Low Carbon Fuel Standard has proven that these types of programs work. RNG is now over 60% of the natural gas usage in the LCFS, and with LA Metro awarding Clean Energy an RNG contract, that number will soon be over 90%. b.There has already been considerable amount of time and money spent over many years outside of Ontario on demonstration programs showing the benefits of using RNG as a transportation fuel with commercially-ready technology available today that can be used for the purposes listed here. We strongly feel that there is no need for OMAFRA to waste additional money and time trying to prove that this is a good idea - again. The time is NOW to start the Green Commercial Vehicle Program.

c.For more information on the benefits of RNG and low-NOx engines, please go here: http://ngvgamechanger.com/pdfs/GameChanger_FullReport.pdf (Full Report 192 pages) http://www.casustainablefreight.org/documents/Comments/175_SoCalGas_02.pdf (Executive Summary 20 pages).

d.For an Analysis of Zero Emission Bus Options, please go here: http://metro.legistar1.com/metro/attachments/140a441a-fb64-4fbd-9612-25272b858f07.pdf

e.For a report on The Feasibility of Renewable Natural Gas as a Large-Scale, Low Carbon Substitute, please go here: https://www.arb.ca.gov/research/apr/past/13-307.pdf

f.For more information on Clean Energy’s Renewable Natural Gas for Transportation product offering, please go here: http://redeem.cleanenergyfuels.com/

For additional information on RNG for Transportation in the North American market, please go to: RNGVC Jobs Report:

Natural Gas Intelligence (May 1) – Renewable Natural Gas Offers California $14 Billion Economic Stimulus Report Says: http://www.naturalgasintel.com/articles/110318-renewable-natgas-offers-california-14b-economic-stim ulus-report-says

Biomass Magazine (May 1) – New study shows economic value of RNG in California: http://biomassmagazine.com/articles/14339/new-study-shows-economic-value-of-rng-in-california

AltEnergyMag.com (May 1) – New Study Shows Renewable Natural Gas in Transportation Can Create Up to 130,000 Jobs and Generate Nearly $14 Billion in Economic Benefits for California: http://www.altenergymag.com/news/2017/05/01/new-study-shows-renewable-natural-gas-in-transportation -can-create-up-to-130000-jobs-and-generate-nearly-14-billion-in-economic-benefits-for-california/26 140/

Waste Today Magazine (May 1) – New study shows economic benefits of RNG as a transportation fuel in California: http://www.wastetodaymagazine.com/article/new-study-shows-encomic-benefits-rng/

Mass Transit Magazine (May 2) – Economic Impacts of Deploying Low NOx Trucks fueled by Renewable Natural Gas: http://www.masstransitmag.com/press_release/12330924/new-study-shows-renewable-natural-gas-in-trans portation-can-create-up-to-130000-jobs-and-generate-nearly-14b-in-economic-benefits-for-california

NGT News (Next-Gen Transportation) (May 2) – Study: RNG in Transportation Boosts Jobs, Economy for California: https://ngtnews.com/study-rng-transportation-promotes-jobs-economic-benefits-california

Green Auto Market (May 2) – This Week’s Top 10: Low emission NGVs and RNG big at ACT Expo, Ports urged to clean up truck air pollution http://greenautomarket.com/weeks-top-10-low-emission-ngvs-rng-big-act-expo-ports-urged-clean-truck- air-pollution/

ACT Now Plan

Green Auto Market (May 2) – This Week’s Top 10: Low emission NGVs and RNG big at ACT Expo, Ports urged to clean up truck air pollution: http://greenautomarket.com/weeks-top-10-low-emission-ngvs-rng-big-act-expo-ports-urged-clean-truck- air-pollution/

Natural Gas Intel (May 3) – NGV Engine Makers, Fleet Operators Urge Faster Move to ‘Clean’ Trucking: http://www.naturalgasintel.com/articles/110329-ngv-engine-makers-fleet-operators-urge-faster-move-t o-clean-trucking

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[Original Comment ID: 209737]