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January 10, 2017

VIA EDGAR

Mr. Coy Garrison, Special Counsel

Securities and Exchange Commission

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

 RE: Agree Realty Corporation

Form 10-K for Fiscal Year
Ended December 31, 2015

Filed March 11, 2016

File No. 001-12928

Dear Mr. Garrison:

This letter is submitted in response to
your comment letter dated December 16, 2016 (the “Letter”) with respect to the Form 10-K for Fiscal Year Ended December
31, 2015 of Agree Realty Corporation (the “Company”), which was filed with the Securities and Exchange Commission (the
“Commission”) on March 11, 2016.

For convenience of reference, your comments
are reproduced in italics, and are followed by the Company’s response.

Form 10-K for Fiscal Year Ended December
31, 2015

Properties, page 16

1. We note your press release dated
October 24, 2016 discussing your development projects. In future Exchange Act periodic reports, please clarify the amount of property
you hold for development and disclose anticipated completion dates, costs incurred to date and budgeted costs. For completed developments,
please disclose development and redevelopment expenditures per square foot and clarify whether you have included leasing costs.
For material amounts of land, please discuss the amount of development the land could support.

RESPONSE

The Company currently discloses the costs
incurred to-date of the properties being developed in the line item titled Property Under Development on its balance sheet. This
line item includes all costs related to the land acquisition, planning, development and construction of properties, including interest
and real estate taxes during the construction period, prior to the date the properties become operational. These costs are capitalized
for financial purposes. Leasing costs associated with the lease up of development properties are included in Property Under Development
prior to the date the development properties become operational. Once operational, the leasing costs are reclassified into Unamortized
Deferred Expenses. See Note 2 to the Company’s Consolidated Financial Statements for additional details regarding the Company’s
significant accounting policies.

In the Company’s appropriate future
Exchange Act periodic filings with the Commission, the Company will include disclosure substantially similar to the following example
regarding its development and redevelopment projects:

“During the third quarter and subsequent
thereto, the Company commenced seven new development and Partner Capital Solutions (“PCS”) projects with total project
costs of $24.8 million. These projects include the Company’s first Texas Roadhouse in Mount Pleasant, Michigan; three new
Burger King developments in Hamilton, Montana, West Fargo, North Dakota and Heber, Utah; two new Camping World projects in Tyler,
Texas and Georgetown, Kentucky; and the redevelopment and expansion of an existing asset for Orchard Supply Hardware in Boynton
Beach, Florida.

Year-to-date, the Company has 14 development
or PCS projects completed or currently under construction on behalf of a number of industry-leading retail tenants. Total project
costs for those developments are approximately $38.0 million and include the following completed or commenced projects:

    Tenant

    Location

    Lease Structure

    Lease Term

    Actual or Anticipated Rent Commencement

    Status

    Hobby Lobby

    Springfield, OH

    Build-to-Suit

    15 Years

    Q1 2016

    Completed

    Burger King

    Farr West, UT

    Build-to-Suit

    20 Years

    Q2 2016

    Completed

    Family Fare Quick Stop

    Marshall, MI

    Ground Lease

    10 Years

    Q2 2016

    Completed

    Burger King

    Devils Lake, ND

    Build-to-Suit

    20 Years

    Q3 2016

    Completed

    Wawa

    Orlando, FL

    Ground Lease

    20 Years

    Q3 2016

    Completed

    Chick-fil-A

    Frankfort, KY

    Ground Lease

    20 Years

    Q3 2016

    Completed

    Starbucks

    North Lakeland, FL

    Build-to-Suit

    10 Years

    Q4 2016

    Under Construction

    Burger King

    Hamilton, MT

    Build-to-Suit

    20 Years

    Q4 2016

    Under Construction

    Burger King

    West Fargo, ND

    Build-to-Suit

    20 Years

    Q1 2017

    Under Construction

    Burger King

    Heber, UT

    Build-to-Suit

    20 Years

    Q1 2017

    Under Construction

    Texas Roadhouse

    Mount Pleasant, MI

    Ground Lease

    15 Years

    Q2 2017

    Under Construction

    Camping World

    Tyler, TX

    Build-to-Suit

    20 Years

    Q2 2017

    Under Construction

    Camping World

    Georgetown, KY

    Build-to-Suit

    20 Years

    Q3 2017

    Under Construction

    Orchard Supply Hardware

    Boynton Beach, FL

    Build-to-Suit

    15 Years

    Q3 2017

    Under Construction”

The Company’s development and redevelopment
activities are a minority piece of its overall investment activity, representing less than 10% of the Company’s investment
activity from 2014 through 2016. Management of the Company believes the project costs of any one individual development or redevelopment
project are immaterial to the Company’s overall investment activities. For these reasons, the Company intends to disclose
aggregate project costs for its entire pipeline of development and redevelopment projects on a quarterly and year-to-date basis.

The Company’s completion timelines
for its development and redevelopment projects are highly variable due to a number of different factors outlined in Item 1a Risk
Factors in the Company’s Annual Report on Form 10-K. As a result of this variability, and in an effort to provide investors
with a reasonable estimate of a development or redevelopment project’s completion, the Company intends to utilize quarterly
rent commencement timelines to indicate when a project is expected to be completed.

The Company’s development and redevelopment
projects include ground lease and traditional lease structures, of which the terms, cost structures and rental rates vary greatly
in material respects from one project to another. The scope of the Company’s development and redevelopment efforts also differ
materially depending on a number of factors specific to the project, including but not limited to the size of the parcel, topography
of the site, size of the building, preferences and needs of the occupying tenant and requirements of the municipality in which
the property is located. In consideration of these factors, the Company does not believe development and redevelopment expenditures
per square foot is a relevant metric when evaluating the cost of its development and redevelopment projects, nor does it believe
development and redevelopment expenditures per square foot provides a useful comparison between periods.

The Company has not historically held material
amounts of land. The Company will continue to monitor and comply with U.S. GAAP requirements and, in the Company’s future
Exchange Act periodic reports, commencing with its Annual Report on Form 10-K for the year ending December 31, 2016, will disclose,
to the extent it has material land holdings, the amount of development the land could support.

The Company acknowledges that:

 § the Company is responsible for the adequacy and accuracy
of the disclosure in the filing;

 § Staff comments or changes to disclosure in response
to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 § the Company may not assert 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 or comments regarding
the foregoing, or have additional questions or comments, please contact the undersigned, at (248) 419-6335 or mpartridge@agreerealty.com,
or Donald J. Kunz, counsel for the Company, at (313) 465-7454 or dkunz@honigman.com.

    Sincerely,

    /s/ Matthew M. Partridge

    Matthew M. Partridge

    Executive Vice President, Chief
    Financial Officer and Secretary

    cc:
    Rahul K. Patel, Securities and Exchange Commission

    Donald J. Kunz, Honigman Miller Schwartz and Cohn LLC

    Josie A. Hunwick, Grant Thornton LLP