December 7, 2018

Desmond Wheatley
Chief Executive Officer
Envision Solar International, Inc.
5660 Eastgate Dr.
San Diego, California 92121

       Re: Envision Solar International, Inc.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed November 14, 2018
           File No. 333-226040

Dear Mr. Wheatley:

       We have limited our review of your amended registration statement to
those issues we
have addressed in our comments. In some of our comments, we may ask you to
provide us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our October 12,
2018 letter.

Amendment No. 2 to Form S-1 filed November 14, 2018

Risk Factors, page 14

1.     We note your response to prior comment 8. Please address in your
description of the
       warrants the exclusive forum provision included in section 5(e) of
exhibit 4.2. Also
       disclose any appropriate risk factors.
Documents Incorporated by Reference, page 95

2.     Please identify the documents that satisfy the criteria mentioned in the
third and fourth
       bullet points of this section.
 Desmond Wheatley
Envision Solar International, Inc.
December 7, 2018
Page 2
Exhibits

3.     We note your response to prior comment 6. Please file the opinion
required by Regulation
       S-K Item 601(b)(5) regarding the Units mentioned in the fee table of
your registration
       statement.
4.     Please reconcile the description of your offering in your prospectus
with the reference to
       issued and outstanding shares in clause (b) of the fourth paragraph of
the attachment to
       your letter to us dated November 14, 2018.
5.     We note the reference to New York law in exhibit 4.2, but the attachment
to your letter to
       us dated November 14, 2018 suggests that the opinion that you intend to
file is limited to
       the General Corporation Law of the State of Nevada. Please file an
opinion that addresses
       all relevant jurisdictions. For guidance, see section II.B.1.f of Staff
Legal Bulletin No. 19
       (October 14, 2011).
6.     Please tell us whether the reference to warrants mentioned in the second
paragraph of the
       prospectus cover includes the Representative Warrant. Also, we note
section 6 d) of
       exhibit 4.4 and the waiver of jury trial provision; please tell us
whether the waiver of jury
       trial would apply to claims under the federal securities laws and the
rules and regulations
       thereunder.
      Please contact Thomas Jones at 202-551-3602 or Russell Mancuso, Branch
Chief, at 202-
551-3617 with any questions.



                                                              Sincerely,
FirstName LastNameDesmond Wheatley
                                                              Division of
Corporation Finance
Comapany NameEnvision Solar International, Inc.
                                                              Office of
Electronics and Machinery
December 7, 2018 Page 2
cc:       Mark Richardson
FirstName LastName