Envision Solar International, Inc.

5660 Eastgate Drive

San Diego, CA 92121


June 2, 2020




Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549


Attention: Edward M. Kelly


  Re: Envision Solar International, Inc.
    Registration Statement on Form S-3 (No. 333-238701)
    Request for Acceleration


Dear Mr. Kelly:


Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Envision Solar International, Inc. (the "Company") hereby requests that the effective date of its Registration Statement on Form S-3 (File No. 333-238701) be accelerated so that the same will become effective at 5:00 p.m., Eastern Time, on Thursday, June 4, 2020, or as soon thereafter as practicable.


If you have any questions regarding this request or the Registration Statement, please call our counsel Jeff Pietsch of Weintraub Tobin, at (415) 772-9611.


  Very truly yours,
  Envision Solar International, Inc.
  By: /s/ Desmond Wheatley
  Desmond Wheatley
  Chief Executive Officer