| Ms. Julie Bell | June 24, 2009 |
| Re: | EVCARCO, Inc. Registration Statement on Form S-1 Amendment 3 Filed May 15, 2009 File No. 333-158293 |
| 1. | We note you revised the number of shares outstanding before the offering and the number of shares outstanding after the offering to reflect 17,510,000 shares. Please advise as it appears that you have 17,533,000 shares outstanding. Response to comment#1: We have updated the shares in the Prospectus to reflect the correct outstanding shares of 17,553,000. This was just an input error. I noticed you stated in note 1 17,533,000 but in fact it should be 17,553,000. |
| 2. | We note that exhibits 10.2, 10.3, and 10.4 we executed on September 26, 2008, September 5, 2008, and September 10, 2008 respectively. We note, however, that Evcarco was not incorporated until October 14, 2008. Please advise. |
Response to comment #2: These agreements were pre-incorporation and while Evcarco was functioning as a d/b/a pending Nevada State Incorporation. |
| · | Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing: |
| · | The action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of this disclosure in the filing: and |
| · | The company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal laws of the United States. |
