SecProbe.io

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September 21, 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

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.

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

     4.   On  September  19,  2005,  the Company  filed Form 10-K/A for the year
          ended December 31, 2004 with the Rule 3-09 of Regulation S-X financial
          statements for the Hyundai-Enova  Innovative Technology Center (HEITC)
          because the 40%  investment in the HEITC exceeded 20% of Enova's total
          assets as of that date. Future filings of Form 10-K will also be filed
          in conformance with this regulation as well as Form 10-Q including the
          disclosure  required  by  Item  4-08(g)  of  Regulation  S-X  for  any
          significant equity method investees above the 20% threshold.  Based on
          the Company's total assets as of the date of this response,  Rule 3-09
          no longer applies to the HEITC as it no longer  represents over 20% of
          the Company's total assets due to a capital  infusion of approximately
          $18 million in July 2005.

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

     5.   Our auditor for the 2002 financial statements was Moss Adams. 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  was no opinion
          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
         Steve Wallaert, Moss Adams
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