October 11, 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.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted September 27, 2019
           CIK 0001584547

Dear Mr. Atkinson:

      We have reviewed your amended 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.

Amendment No. 1 to Draft Registration Statement on Form F-1 submitted September
27, 2019

Plan of Operations, page 23

1.     We note that you disclose your plans to build a manufacturing facility,
and disclose that
       you are in the process of obtaining building permits to commence
construction of the
       facility. Please disclose the timeline for your plan to commence such
construction. In that
       regard, we note your response to prior comment 5.
Employment, Consulting and Management Agreements, page 48

2.     We note your disclosure on page 48 that you entered into a management
services
       agreement with Koko Financial Services, Inc., pursuant to which such
company's
       designated personnel is to be engaged by your company "with the duties
set out in the
 Fraser Atkinson
GreenPower Motor Company Inc.
October 11, 2019
Page 2
         management services agreement." Please revise to describe such duties.
In that regard,
         we note that you have omitted the schedule from the management
services agreement filed
         as Exhibit 10.1.
Share Ownership, page 52

3.       Where you disclose the beneficial ownership of your common shares,
please include
         common shares that the person has the right to acquire within 60 days
by option or other
         agreement. Refer to the definition of "beneficial owner" in General
Instruction F of Form
         20-F. For example, where you quantify the beneficial ownership of your
common shares
         by Fraser Atkinson on pages 52 and 57, it does not appear that you
have included all
         common shares that he has the right to acquire within 60 days pursuant
to options,
         warrants, or convertible debentures.
       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
October 11, 2019 Page 2                                      Office of
Manufacturing
FirstName LastName