April 14, 2020

Jeffrey Shepherd
Executive Vice President, Chief Financial Officer
Advance Auto Parts, Inc.
2635 East Millbrook Road
Raleigh, NC 27604

       Re: Advance Auto Parts, Inc.
           Form 10-K for the Fiscal Year Ended December 28, 2019
           Item 2.02 Form 8-K Filed February 18, 2020
           File No. 001-16797

Dear Mr. Shepherd:

       We have reviewed your filings 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 business days by providing
the requested
information or advise 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.

Form 10-K for the Fiscal Year Ended December 28, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Reconciliation of Non-GAAP Financial Measures, page 21

1.    Please tell us and revise your reconciliations for each period presented
to show the amount
      related to each material component of transformation expenses separately
(e.g.,
      restructuring costs, store closure costs, third-party professional
services and other
      significant costs). Please also tell us and disclose in greater detail
the specific third-party
      professional services and other significant costs that are being removed.
Financial Statements, page 33

2.    On page 21, you state that restructuring and store closure costs are
included in
      transformation expenses. Please tell us and disclose in the footnotes to
your financial
      statements the information required by ASC 420-10-50-1 and SAB Topics
5.P.3 and
      5.P.4.
 Jeffrey Shepherd
Advance Auto Parts, Inc.
April 14, 2020
Page 2
Item 2.02 Form 8-K Filed February 18, 2020

Exhibit 99.1
Reconciliation of Non-GAAP Financial Measures

3.       Please revise your reconciliation to Adjusted EBITDA to begin with net
income and
         present each material adjustment separately. Refer to the guidance in
Question 103.02 of
         the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations and Item
         10(e)(1)(i)(B) of Regulation S-K.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Blaise Rhodes at (202) 551-3774 or Rufus Decker at (202)
551-3769 if
you have any questions.



FirstName LastNameJeffrey Shepherd                           Sincerely,
Comapany NameAdvance Auto Parts, Inc.
                                                             Division of
Corporation Finance
April 14, 2020 Page 2                                        Office of Trade &
Services
FirstName LastName