June 22, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention: Julie Sherman

         Re:      Enova Systems, Inc.
                  Responses to Comments
                  Form 10-K for the year ended December 31, 2004
                  Filed March 31, 2005
                  SEC File No. 0-25184

Dear Ms. Sherman:

In response to the SEC's  comments on the Form 10-K for the year ended  December
31, 2004, Enova Systems submits the following responses:

The 2004 Amended 10-K will include  audited  financials for the ITC (as noted in
Item 4 below) which will require  additional time to complete,  anticipated,  at
this time, to be September 15, 2005.

Item 9a, Controls and Procedures, page 37
- -----------------------------------------

1.            The  Company   acknowledges  its  understanding  that  it  is  not
              appropriate  to  qualify  its  conclusion   with  respect  to  the
              effectiveness of its disclosure controls and procedures.

              Future filings will include revised language to be consistent with
              the definition of disclosure  controls and procedures set forth in
              Rule 13a-15(e) of the Exchange Act.

2.            All future filings will include additional  disclosures that, "the
              Company's system of internal  control over financial  reporting is
              designed to provide reasonable assurance that the objective of the
              system  will be met," and "that the  design and  operation  of our
              system  of  internal  controls  does  in fact  provide  reasonable
              assurance in achieving the  objectives  of the system"  consistent
              with Part II.F.4 of Release No. 33-8238.

3.            All future 10-K filings  commencing  with our 2005  year-end  will
              address changes in our internal  control over financial  reporting
              to indicate  whether there was any change in our internal  control
              over financial  reporting that occurred  during the fourth quarter
              that has materially affected or is reasonably likely to materially
              affect our internal  control over financial  reporting as required
              by Item 308(c) of Regulation S-K as amended  effective  August 13,
              2003.





Note 1. Organization and Line of Business, page 11
- --------------------------------------------------

4.            The 2004  Amended  10-K and all future  filings  will include Rule
              3-09 of Regulation S-X financial  statements for the Hyundai-Enova
              Innovative  Technology Center (HEITC) for those years in which the
              40%  investment  in the HEITC exceed 20% of Enova's  total assets.
              Future  Form 10-Qs will  include the  disclosures required by Item
              4-08(g)  of  Regulation  S-X for  any  significant  equity  method
              investees above the 20% threshhold.

Supplemental Information, page 30
- ---------------------------------

5.            Our auditor for the 2002 financial statements was Moss Adams, LLP.
              Although  Rule 5-04 of Regulation  S-X requires  Schedule II to be
              filed for each  period for which an audited  income  statement  is
              provided,  we also  understand  that the rule  states  that if the
              information,  including  notes,  required by the  schedule  can be
              shown in the  financial  statements  without  making the statement
              unclear  or   confusing,   then  the   schedule  may  be  omitted.
              Additionally, under Rule 4-02, if the amount is not material, this
              Rule provides that it does not need to be presented.

              For the year  ended  December  31,  2002,  there was no  valuation
              allowance  against  receivables  as all  receivables  were  deemed
              collectible.  The allowance against inventory, which was unchanged
              at  $80,000  since  2000,  was  deemed  immaterial.   Therefore  a
              Supplemental  Information  schedule was not provided for that year
              and therefore no opinion was rendered.

The Company acknowledges:

       o      it is responsible  for the adequacy and accuracy of the disclosure
              in the filings;

       o      SEC staff  comments or changes to  disclosure in response to staff
              comments in the filings reviewed by the staff do not foreclose the
              Commission from taking any action with respect to the filing; and

       o      it  may  not  assert  any  staff  comments  as a  defense  in  any
              proceeding  initiated  by the  Commission  or any person under the
              federal securities laws of the United States.

If you have  any  questions  regarding  these  matters,  you may  contact  me at
310-527-3847.

                                                     Very truly yours,

                                                     ENOVA SYSTEMS, INC.

                                                     By: /s/ Larry Lombard
                                                     ---------------------------
                                                     Larry Lombard
                                                     Chief Financial Officer


cc:      Don Dreyer, Audit Committee Chairman
         Edwin Riddell, President and CEO
         Don Reinke, General Counsel
         Elberta Yee, Singer Lewak
         Greenbaun & Goldstein, LLP
         Steve Wallaert, Moss Adams