SecProbe.io

December 29, 2014

Via E -mail
Eugene Shnayderman
Chief Accounting Officer and Controller
Getty Realty Corp.
Two Jericho Plaza, Suite 110
Jericho, New York 11753

Re: Getty Realty Corp.
 Form 10-K for Fiscal Year Ended December 31, 2013
Filed March 17, 2014
File No. 001 -13777

Dear Mr. Shnayderman :

We have reviewed your filing an d 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 within ten business days by amending your filing, 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 or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Item 1. Business, page 5

Company Operations, page 5

1. We note that the majority of your leases are triple -net leases.  In future Exchange Act
periodic reports, please provide disclosure regarding how you monitor the credit quality
of your tenants.

Item 7 .  Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 29

2. In future Exchange Act periodic reports, please provide disclosure that addresses period
to period changes in same store performance, addressing the relative impact o f occupancy
and rental rate changes.

Eugene Shnayderman
Getty Realty Corp.
December 29, 2014
Page 2

 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 Securities Exchange Act of
1934 and all applicable Exch ange 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 made.

 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 of the United States.

Please contact Sara von Althann  at (202) 551 -3207  or me at (202) 551 -3233  with any
questions.

Sincerely,

 /s/ Tom Kluck

        Tom Kluck
Legal Branch Chief