September 24, 2019

Luis Zavala
Chief Financial Officer
Polar Power, Inc.
249 E. Gardena Blvd.
Gardena, CA 90248

       Re: Polar Power, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed April 1, 2019
           File No. 001-37960

Dear Mr. Zavala:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended December 31, 2018

Notes to Financial Statements
Note 1 - Organization and Summary of Significant Accounting Policies
Revenue, page F-7

1.    We note the discussions on pages 10 and 11 relating to the different
services you offer to
      your customers. Please revise this note in future filings to address the
following:

          Identify each source of revenue and explain how you account for that
revenue ("point-
          in-time" or "over time").
          Explain how you account for revenues from your ongoing system
performance
          monitoring service offered as part of your global network management
services, which
          appears to also include software updates to customers.
          Address your accounting for revenues from the rental equipment you
deploy to
          customer facilities.
 Luis Zavala
Polar Power, Inc.
September 24, 2019
Page 2


2.       We note from pages 10 and 11 that the warranties you offer to
customers appear to
         include a promise of additional future services in addition to the
usual assurance that your
         products will function as expected. Also, from page F-8 we note that
your product liability
         balance excludes 'the deferred revenues related to [your] warranty
coverage'. Please
         revise this note in future filings to clearly describe your future
performance obligations
         under the warranties you provide to customers and explain how you
allocate and account
         for the amount of the transaction price related to these obligations.
Refer to ASC 606-10-
         55-30 thru 35.

Item 15. Exhibits, Financial Statement Schedules
Exhibits 31.1 and 31.2, page 65

3.       We note that the certifications provided do not include the language
in paragraph 4
         referring to your internal control over financial reporting. Please
amend the filing to
         provide revised certifications that include the required wording. You
may file an
         abbreviated amendment that is limited to the cover page, explanatory
note, signature page
         and paragraphs 1, 2, 4 and 5 of the certification. Refer to Exchange
Act Rule 13a-14(a)
         and Item 601(b)(31) of Regulation S-K. This comment also applies to
your Forms 10-Q
         for the periods ended March 31, 2019 and June 30, 2019.
       In closing, 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.

       You may contact David Burton at (202) 551-3626 or Martin James, Senior
Assistant
Chief Accountant, at (202) 551-3671 with any questions.



FirstName LastNameLuis Zavala                                  Sincerely,
Comapany NamePolar Power, Inc.
                                                               Division of
Corporation Finance
September 24, 2019 Page 2                                      Office of
Electronics and Machinery
FirstName LastName