SecProbe.io

December 31, 2014

Via E -mail
Joshua Dicker
Senior Vice President and General Counsel
Getty Realty Corp.
Two Jericho Plaza, Suite 110
Jericho, New York 11753

Re: Getty Realty Corp.
  Registration Statement on Form S-3
Filed  December 12, 2014
  File No.  333-200913

Dear Mr. Dicker :

We have limited our review of your registration statement to those issues w e have
addressed in our comment .  Please respond to this letter by amending your registration statement
as applicable and providing the requested information .  After reviewing any amendment to your
registration statement and the information you provide in response to this comme nt, we may
have  additional comments.

General

1. As you know, we are reviewing your Form 10 -K for the fis cal year ended December 31,
2013 , and have issued comments in connection with that review.  Please confirm that you
will amend the registration statement , as appropriate, to reflect your responses to our
comments on the Form 10 -K.  In addition, please note that we will not be in a position to
declare the registration statement effective until you have resolved all comments raised
on the Form 10 -K.

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 Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its man agement 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.

Notwithstanding our comment , in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

Joshua Dicker
Getty Realty Corp.
December 31, 2014
Page 2

  should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant t o delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding reques ts for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities  Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective  date of the
registration statement.

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

Sincerely,

 /s/ Tom Kluck

 Tom Kluck
Legal Branch Chief

cc: David Chalk , DLA Piper LLP (US) , Via E -mail