April 9, 2019

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

       Re: Envision Solar International, Inc.
           Amendment No. 7 to Registration Statement on Form S-1
           Filed April 8, 2019
           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 April 3,
2019 letter.

Amendment No. 7 to Registration Statement on Form S-1

General

1.     We note your response to prior comment 2 and your revised disclosure on
the prospectus
       cover page the split is not reflected in the financial statements. We
also note your
       disclosure on page 13 which indicates that the reverse split must occur
prior to
       effectiveness of this registration statement. Please tell us the
authority on which you rely
       for your conclusion that the split need not be reflected in your
financial statements.
2.     We note your response to prior comment 6. However, given section 5.f of
exhibit 4.2, and
       section 6.d of exhibit 4.4 with section 7.6 of exhibit 1.1, please tell
us the purpose of the
       deletions from pages 31 and 107 of your prospectus. Also, disclose
whether the forum
       provisions apply to actions arising under the Securities Act or Exchange
Act.
 Desmond Wheatley
Envision Solar International, Inc.
April 9, 2019
Page 2
3.     Please clarify your disclosure on your prospectus cover that "the last
reported sales price
       for [y]our common stock as quoted on the OTC-QB Market" was $9.00 per
share on April
       3, 2019 if there was no sale at $9.00. We note your disclosure "on a
post reverse split
       basis," but we also note your first full risk factor on page 29.
      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
April 9, 2019 Page 2
cc:       Mark Richardson
FirstName LastName