SecProbe.io

May 10, 2012
 Via E-mail

Michael Norona Executive Vice President and Chief Financial Officer Advance Auto Parts, Inc. 5008 Airport Road Roanoke, VA 24019
Re: Advance Auto Parts, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 28, 2012 File No. 001-16797

Dear Mr. Norona:
 We have reviewed your filing and 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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Critical Accounting Policies, page 31

1. We note your disclosure thr oughout Management’s Discussion and Analysis of Financial
Condition and Results of Operations that hi gher shrink expense was one of the factors
contributing to a decrease in gross profit comp ared to the prior year.  Please supplement
your discussion here to discuss how accurate your estimates have been in the past and
whether your estimates have changed signi ficantly in the past  based on physical
inventory counts or other factor s.  Further, please tell us the reason(s) for the increase in
shrink during fiscal 2011.  You disclose the r easons you could be required to revise your
estimates of required reserves in the future, however it is not clea r if there was one or
several factors contributi ng to the increase in shrink expense in fiscal 2011.

Michael Norona Advance Auto Parts, Inc. May 10, 2012 Page 2

 Item 8.  Financial Statements and Supplementary Data

 Notes to the Consolidated Fi nancial Statements, page F-9

 17. Contingencies, page F-31

2. We refer you to the lawsuits regarding expos ure to asbestos-containing products.  Based
on your disclosure a material adverse verdict ap pears reasonably possible.   If there is at
least a reasonable possibility that a loss exceeding amounts already recognized may have
been incurred, in your next periodic filing, please either disclose an estimate (or, if true,
state that the estimate is immaterial in lie u of providing quantified amounts) of the
additional loss or range of loss,  or state that such an estimate cannot be made.  Please
refer to FASB ASC 450-20-50.

If you conclude that you cannot estimate the reasonably possible addi tional loss or range
of loss, please supplementally explain to  us: (1) the procedures you undertake on a
quarterly basis to attempt to develop a range  of reasonably possibl e loss for disclosure
and (2) for each material matter, what specif ic factors are causing the inability to estimate
and when you expect those factor s to be alleviated.  We r ecognize that there are a number
of uncertainties and po tential outcomes associated with lo ss contingencies.  Nonetheless,
an effort should be made to develop estim ates for purposes of disclosure, including
determining which of the potential outcom es are reasonably possible and what the
reasonably possible range of losses would be  for those reasonably possible outcomes.

Note 21.  Segment and Related Information, page F-37

3. We note your disclosure on page 3 that stor es within your AAP reportable segment are
operated and divided into three geographic areas and that this  segment also includes your
e-commerce operations.  Please tell us the operating segments you have identified for
each reportable segment and expand your disclo sure to state whether operating segments
have been aggregated.  See FASB ASC 280-10-50-21.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

Michael Norona Advance Auto Parts, Inc. May 10, 2012 Page 3

  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 federa l securities laws of  the United States.

You may contact Scott Stringer , Staff Accountant, at (202) 551-3272 or Donna Di Silvio,
Staff Accountant, at (202) 551-3202 if you have questions regarding our  comments.  You may
contact me at (202) 551-3720 with any other questions.

Sincerely,
    /s/ Andrew D. Mew
 Andrew D. Mew Accounting Branch Chief