SecProbe.io

August 22 , 2012

Via Facsimile
Mr. Thomas J. Stirnweis
Vice President and Chief Financial  Officer
Getty Realty Corp .
125 Jericho Turnpike, Suite 103
Jericho , NY 11753

Re: Getty Realty  Corp .
  Form 10 -K for the Year Ended December 31, 2011
  Filed March 15 , 201 2
  File No. 1-13777

Dear M r. Stirnweis :

We have reviewed your filing an d have the following comment s.  In our comment s, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter via EDGAR within ten business days by providing the
requested information  or by advising us when you will provide the requested response.   If you do
not believe our comments apply to your facts and circumstances, please tell us why in your
response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Item 7. Management’s Discussion and Analysis of Financial Condition…, pa ge 33

1. In future Exchange Act reports, please revise your disclosure to discuss your leasing
activities for the reported period, including a discussion of the volume of new or renewed
leases, average rents or yields, and, where applicable, average tenant i mprovement costs,
leasing commissions, and tenant concessions.  Also discuss the average market rents
trends, including the impact of tenant reimbursements.

Capital Expenditures, page 45

2. Please quantify for us the amount of capital expenditures other tha n property acquisitions
for the years ended December 31, 2011, 2010, and 2009, and where material, in future
Exchange Act reports please separately disclose these amounts here and in the
consolidated statements of cash flows.

Mr. Thomas J. Stirnweis
Getty Realty Corp.
August 22,  2012
Page 2

 Notes to Consolidated Financi al Statements, page 58

Note 1. Summary of Significant Accounting Policies, page 58

3. It appears that you account for all environmental remediation costs as asset retirement
obligations under ASC 410 -20.  Please tell us how you determined that you did not h ave
any environmental obligations under ASC 410 -30.  Refer to ASC 410 -20-15-3(b).

Note 3. Commitments and Contingencies , page 62

4. In future Exchange Act reports, p lease revise to disclose the amount of reasonably
possible losses or range of losses in excess of amounts accrued for asset retirement
obligations, legal proceedings, and other contingencies or, where applicable, to state that
such an estimate of the possi ble loss or range of loss cannot be made .  Refer to ASC 410 -
30-50 and ASC 450 -20-50.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securitie s Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have m ade.

 In responding to our comments, please provide  a written statement from the company
acknowledging 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 o f the United States.

You may contact Jonathan Wiggins , Staff Accountant,  at (202) 551 -3694 or me at (202)
551-3429  if you have any questions.

Sincerely,

 /s/ Kristi Marrone

 Kristi Marrone
    Staff Accountant