SecProbe.io

July 13, 2015

Michael A. Norona
Chief Financial  Officer
Advance Auto Parts
5008 Airport Road
Roanoke, VA  24012

Re: Advance Auto Parts
 Form 10-K for the Fiscal Year Ended January 3, 2015
Filed March 3 , 2015
File No. 001 -16797

Dear M r. Norona :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operati ons

Consolidated Results of Operations, page 26

1. We note that your disclosure of the net sales analysis for all periods presented includes a
discussion of changes in comparable store sales driven by increases or decreases in
“traffic,” “average transactio n amount” and/or “transaction count.”  If these are key
metrics reviewed by management, we would generally expect you to quantify the
metric(s) for each period presented in addition to explaining how it impacted the change
in your net sales.  As part of yo ur response, please quantify these metrics to help us better
understand how they impacted your results.  We remind you that the principal objectives
of MD&A include providing readers with a view of the company through the eyes of
management.  To do this, c ompanies should include a discussion of the key variables and
other qualitative and quantitative factors which are peculiar to and necessary for an
understanding and evaluation of the individual company.  See Section III.B.1 of SEC

Michael A. Norona
Advance Auto Parts
July 13, 2015
Page 2

 Release No. 33 -8350 and Part III.A of SEC Release No. 33 -6835.  We may have further
comments after considering your response.

2. We note from your results of operations disclosures on page 25 that Commercial drove
increases in 2014 comparable store sales and a decrease in your gros s profit rate and that
the sales increase was partially offset by DIY sales movements.  Please separately
quantify and explain the reasons for the changes in the comparable store sales and gross
profit of your Commercial and DIY operations.  It appears suc h information would be
useful to investors considering your disclosures on page 5 indicate that Commercial is
your “growth engine” and that you “have concentrated a significant amount of our
investment on increasing our Commercial sales.”  We further note from the prepared
remarks during the Q4 2014 earnings call that “the commercial business led the way
during the quarter once again delivering strong comparable store sales gains” and that the
“DIY business continued its uneven sales trends” and “delivered inconsistent
performance in 2014.”  Additionally,  considering you classify costs associated with your
Commercial delivery program within SG&A expense, please explain to us what
consideration you gave to presenting and discussing the results of your Commercial and
DIY businesses  at a level below gross profit.

Item 8. Financial Statements and Supplementary Data

Notes to the Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies, page F -9

3. Based on the prepared remarks included within the Q1 2015 earnings call, we note that
your Speed Perks loyalty program is one of three initiatives you expect to improve your
DIY business.  Please tell us more about your loyalty program accounting policies along
with what consideration you gave to disclosing these details within your filing.

Note 4. Acquisitions, page F -17

4. We note that you allocated approximately 56% of your General Parts International, Inc.
(“GPI”) purchase price to inventory.  Based on  the pro forma financial statements
included in Exhibit 99.4 of your Form 8 -K/A filed November 25, 2013, we note that,
although not a final determination, you assumed no inventory fair value adjustments
since a “preliminary review of the nature, condition and age of GPII’s inventory indicates
the assets’ fair value equals their book value.”  Please tell us the fair value adjustment
you recorded related to GPI I’s inventory and explain to us in sufficient detail how your
treatment complied with GAAP.  For exa mple, demonstrate to us, if applicable, that the
inventory amount recorded reflected estimated selling price less the sum of costs of
disposal and a reasonable profit allowance for your selling effort.  See ASC 820 -10-55-
21.

Michael A. Norona
Advance Auto Parts
July 13, 2015
Page 3

 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 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 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 com pany 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.

You may contact Jason Niethamer, Assistant Chief Accountant, at 202-551-3855,
Andre w Blume , Staff Accountant, at 202 -551-3254 or me at 202-551-3737 with any questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief

Cc: Jill Livesay