SecProbe.io

Mail Stop 3561
July 6, 2016

Mr. Thomas R. Greco
Chief Executive  Officer
Advance Auto Parts, Inc.
5008 Airport Road
Roanoke, VA 24012

Re: Advance Auto Parts, Inc.
 Form 10-K for the Fiscal Year Ended January 2, 2016
Filed March 1, 2016
Form 8 -K Filed May 19, 2016
File No. 1 -16797

Dear Mr. Greco :

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 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.

Financial Statements

2. Inventories, net , page F -17

1. You state on page F -10 that inventory amounts a re stated at the lower of cost or market.
Please explain in detail how you determine market, as defined in ASC 330 -10-20.  We
note that the cost of your merchandise inventory is primarily determined using the LIFO
method and that you determine inventories  at FIFO, net and make an adjustment to state
them at LIFO, net.  If our understanding is incorrect, please clarify. If our understanding
is correct, please tell us how you determine the LIFO adjustment and whether it is based
on actual prices, given your use of a perpetual inventory system.  We also note that LIFO
cost is greater than FIFO cost and you present your inventory balance inclusive of a
negative LIFO reserve. Please tell us in detail why you adjusted your inventory to the
higher LIFO cost basis.   On this point, please specifically explain how you applied the
lower of cost or market principle in ASC 330 -10-35 and whether inventory determined

Mr. Thomas R. Greco
Advance Auto Parts, Inc.
  July 6 , 2016
Page 2

 under FIFO could be considered a proxy for replacement cost.  If inventory is stated on
the higher LIFO cos t basis because evidence indicates that cost will be recovered with a
normal profit upon the sale in the ordinary course of business, please tell us how you
determined “a normal profit” and whether it is based on a LIFO or FIFO cost assumption.
Please prov ide support for your conclusions and be comprehensive in your response.  We
may have further comment.

Form 8 -K Filed May 19, 2016

2. You disclose adjusted cash EPS in the headline without a comparable GAAP measure,
present tabular disclosure of non -GAAP f inancial measures without preceding it with an
equally prominent tabular disclosure of the comparable GAAP measures, discuss non -
GAAP measures before the most directly comparable GAAP measure and present a full
non-GAAP income statement when reconciling no n-GAAP measures to the most directly
comparable GAAP measure .  These items  may be inconsistent with Question 102.10 of
the updated Compliance and Disclosure Interpretations  on Non -GAAP Financial
Measures issued on May 17, 2016.  Please review this guidance when preparing your
next earnings release.

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.

You may  contact  Yong  Kim, Staff  Accountant, at (202)  551-3323  or me at (202) 551 -
3849 with  any questio ns.

Sincerely,

 /s/ James Allegretto

James Allegretto
Senior Assistant Chief Accountant
Officer of Consumer Products