SecProbe.io

Mail Stop 3561

    December 31, 2007
 By Facsimile and U.S. Mail

 Michael O. Moore Executive Vice President,   Chief Financial Officer Advance Auto Parts, Inc. 5008 Airport Road Roanoke, VA 24012
  Re: Advance Auto Parts, Inc.
   Form 10-K for Fiscal Year Ended December 30, 2006
   Filed February 28, 2007    File No. 001-16797    Definitive Proxy Statement on Schedule 14A   Filed April 11, 2007    File No. 001-16797
Dear Mr. Moore:

 We have reviewed your filings and have the following comments.  Please provide
a written response to our comments.  Pleas e be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for Fiscal Year Ended December 30, 2006

Critical Accounting Policies, page 25

1. We note that you maintain reserves for your inventory.  In future filings, please
include these reserves in your Schedule  II provided under Regulation S-X Rule 5-
04(a).  We also note that there was a si gnificant increase in the inventory reserve

Mr. Michael O. Moore
Advance Auto Parts, Inc.
December 31, 2007  Page 2
in the most recent fiscal year.  The reas ons for this increase should be discussed
either hear or elsewhere in mana gement’s discussion and analysis.

2. We note that you accrue reserves for self insurance.  Please tell us why these
reserves increased significantly from December 30, 2005 to December 31, 2006.  In future filings, please provide a tabl e that reconciles beginning and ending
balances by disclosing additions, utilization and adjustments to the accrual.  This table can be presented either as part of this discussion, in  the notes to your
financial statements or as part of Sc hedule II.  You should discuss significant
changes in the accrual as part of your di sclosures of critical accounting policies.

Notes to Consolidated Financial Statements, page F-10

3. We note your website states you accept us ed auto batteries when you sell new
batteries.  Please tell us if there are any environmental costs or obligations
associated with this business practice.  Tell us whether you use a third party to
dispose of or recycle the batteries.  Conf irm that you are in compliance with state
laws that either mandate the recycling of lead acid batteries  or prohibit their
disposal in landfills.

Sales Returns and Allowances, page F-12

4. Please include your reserves for sales retu rns and allowances as part of your
Schedule II.
 10. Accrued Expenses, page F-23

5. Please explain to us why you have ac crued expenses related to capital
expenditures.
 14. Income Taxes, page F-26

6. Tell us why there is a large deferred tax lia bility associated with your inventory.
Explain to us in detail the specific caus es that result in your inventory being
significantly lower for tax purposes than for GAAP purposes.
 20. Segment and Related Information, page F-34

 7. In your business discussion you state that  similar product categories contribute
different levels of profitability to your operations and also describe product sales
by groups such as replacemen t parts, maintenance items and general accessories.
We refer you to pages 3 and 6.  Please tell us why you have not included the
disclosures required by paragraph 37 of  SFAS No. 131.  Alternatively, please
provide us with an example of your proposed disclosure for future filings.

Mr. Michael O. Moore
Advance Auto Parts, Inc.
December 31, 2007  Page 3   Schedule 1 - Condensed Financial Information of the Registrant, page F-37

8. Please tell us how the current disclosure  satisfies the requirements concerning
restrictions on dividends and retained earnings or net income.  See Rule 4-
08(e)(3)(i) and (ii) and Rule 5-02.31(a)(3 ) of Regulation S-X.  If there are no
restrictions between parent and subsidiaries please disc lose this fact in future
filings.
 Definitive Proxy on Schedule 14A

 Compensation Discussion & Analysis, page 13

 Base Salary, page 14

9. You indicate that you compare your base sala ries to the competitive retail market
data provided by HayGroup.  Clarify whether the information provided by
HayGroup differs from the peer group of companies you disclose above.  If it
does and considering you appear to be benchmarking this amount, please identify
the benchmark and its components, pur suant to Item 402(b)(2)(xiv).
 10. You disclose that base sala ry levels for your executives are below the median for
the retail market.  You also disclose that  you intend to increase salaries to a level
approaching the median of the retail market.  Disclose in more detail why current base salaries are below the median for your market group.  Disclose how you plan
to implement the proposed salary increas es.  For example, disclose the time
period over which these increases are expected  to take place as well as if there are
any predetermined increases, either in w hole dollar amounts or as a percentage of
salary, which you plan to implement in orde r to close the gap.  Please provide us
with an example of your proposed revisions  to your disclosure.  See Regulation S-
K Item 402(b)(1)(v).

11. We note that you consider the performa nce of the individual executive in
determining the base salary.  Enhance your disclosure to more specifically
identify what aspects of performance are considered and how they impact any changes to base salary.  See Re gulation S-K Item 402(b)(2)(vii).

12. We note that there have been material in creases in the annual  base salaries of
several of your executives.  Please tailor your discussion to  discuss the factors that
contributed to these material increases .  See Regulation S-K Item 402(b)(2)(ix)
and instruction (2) to Item 402(b).

Mr. Michael O. Moore
Advance Auto Parts, Inc.
December 31, 2007  Page 4  Annual Incentive Plan, page 14

13. We note that a significant portion of your incentive bonus is tied to performance
relative to budgeted amounts.  We also note that the bonus paid pursuant to the
incentive plan is targeted to be a signif icant portion of total compensation.  Given
that budgets are subjective please expand your disclosure  to more specifically
address how you determine budgeted sales and operating income targets.  Disclose the amounts used for budgeted sales and operating income for 2006 and
2007 and provide a brief analysis of how you chose these amounts.  To the extent you believe disclosure of these targets is  not required because it could result in
competitive harm, provide us on a supplem ental basis a detailed explanation for
this conclusion.  See instruction 4 to Item  402(b).  If disclosure of the targets
would cause competitive harm, please discuss further how difficult it will be for the named executive officer or how likely it will be for you to achieve the target levels or other factors.  See Regulation S-K Item 402(b)(1)(v).
 Long Term Incentive Compensation, page 15

14. We note your disclosure that option grants are based upon an executive’s
performance relative to stock option gui delines.  Expand your disclosure to
discuss the elements of individual perf ormance and the stock option guidelines.
See Regulation S-K Item 402(b)(2)(vii).

15. Your disclosures in the section titled “Setting Executive Compensation” indicate
that total compensation will be determ ined based upon a comparison of your
earnings per share growth with that of your peers.  Discuss in more detail how this
objective will impact your determination of long term incentive compensation.
See Regulation S-K Item 402(b)(1)(v).

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

Mr. Michael O. Moore
Advance Auto Parts, Inc. December 31, 2007  Page 5
• the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

• staff comments or changes to disclosu re in response to staff comments do
not foreclose the Commission from ta king any action with respect to the
filings; and

• the company may not assert staff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.
   In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.
 You may contact Brian McAllister, Staff Accountant, at (202) 551- 3341 or
Michael Moran, Accounting Branch Chief at  (202) 551-3841 if you have any questions
regarding the financial stat ements and related matters.  Please contact Anita Karu,
Attorney-Advisor, at 202-551-3240, Mara Rans om, Legal Branch Chief, at (202) 551-
3264, or me at (202) 551-3725 with any other questions.

    Sincerely,

 H. Christopher Owings
Assistant Director