September 10, 2019

Fraser Atkinson
Chief Executive Officer
GreenPower Motor Company Inc.
#240 - 209 Carrall Street
Vancouver, British Columbia V6B 2J2, Canada

       Re: GreenPower Motor Company, Inc.
           Draft Registration Statement on Form F-1
           Submitted August 14, 2019
           CIK 0001584547

Dear Mr. Atkinson:

       We have reviewed your draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement Submitted August 14, 2019

Risk Factors, page 5

1.     Please add a risk factor addressing the fact that your shareholders
approved a shareholder
       rights plan which may be implemented by management and may impede a
change in
       control.
Government Regulation, page 22

2.     To the extent material please discuss battery disposal requirements
including the costs
       borne by you and by customers.
 Fraser Atkinson
FirstName LastNameFraser Atkinson
GreenPower Motor Company Inc.
Comapany 10, 2019
September NameGreenPower Motor Company Inc.
September 10, 2019 Page 2
Page 2
FirstName LastName
Capitalization and Indebtedness, page 26

3.       We refer to your capitalization table. Please clarify for us and
revise your disclosures to
         explain the reason(s) for the change in the liability amounts related
to line of credit,
         secured and unguaranteed debt, and unsecured and unguaranteed debt
under the As
         Adjusted column. It is unclear from your disclosures why total
indebtedness on an as
         adjusted basis would decrease as a result of the issuance of
13,114,754 common shares to
         selling shareholders and an additional 6,557,371 common shares
issuance upon exercise
         of warrants by the selling shareholders.
Operating and Financial Review and Prospects, page 27

4.       In your discussion of operating results please quantify and discuss
each significant
         component of costs comprising cost of sales and separately disclose,
quantify, and discuss
         the underlying reasons for each material variance in the components of
cost of sales.
Liquidity and Capital Resources, page 29

5.       Please discuss the impact that expanding your manufacturing
capabilities in Porterville
         will have on your liquidity and capital resources, to the extent that
this represents a
         material trend. Refer to Item 5.D of Form 20-F.
Operating and Financial Review and Prospects
Tabular Disclosure of Contractual Obligations, page 40

6.        As the contractual obligation table is aimed at increasing
transparency of cash flow, we
         believe that registrants should include scheduled interest payments in
the table. To the
         extent that interest rates are variable and unknown, you may use
judgment to determine
         which interest rates to use. Accordingly, please consider including
the scheduled interest
         payments and footnote disclosure of the interest rate used and how it
was determined.
Financial Information
Note 1. Nature and Continuance of Operations, page F-10

7.       We note your statement "To this end, the Company has now delivered and
received
         payment for all-electric buses to customers, ..." In the regard,
please tell us the nature
         of accounts receivable balance of approximately $1.4 million as of
March 31, 2019.
Exhibits

8.       Please file agreements with your third party manufacturers and
suppliers as exhibits to
         your registration statement. We note on pages 6 and 8 that you are
dependent upon these
         manufacturers. In addition, file your distribution agreement with your
primary
         distributor Creative Bus Sales. Alternatively tell us why these
agreements are not
         required to be filed. Refer to Item 601(b)(10) of Regulation S-K.
 Fraser Atkinson
GreenPower Motor Company Inc.
September 10, 2019
Page 3
General

9.       It appears you have made available more current financial information
than otherwise
         required by Item 8 of Form 20-F. In this regard, please revise to
include interim financial
         information for the period ended June 30, 2019 and update the affected
sections of the
         filing as applicable.
       You may contact Aamira Chaudhry at 202-551-3389 or Jean Yu at
202-551-3305 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Dana Brown at 202-551-3859 or Laura Nicholson at 202-551-3584 with any
other
questions.



FirstName LastNameFraser Atkinson                              Sincerely,
Comapany NameGreenPower Motor Company Inc.
                                                               Division of
Corporation Finance
September 10, 2019 Page 3                                      Office of
Transportation and Leisure
FirstName LastName