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                            July 28, 2020

       Jonathan Benfield
       Chief Financial Officer
       CrossAmerica Partners LP
       600 Hamilton Street, Suite 500
       Allentown, PA 18101

                                                        Re: CrossAmerica
Partners LP
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 26,
2020
                                                            Form 8-K Filed
February 26, 2020
                                                            Form 10-Q for the
Quarterly Period Ended March 31,2020
                                                            Filed May 7, 2020
                                                            File No. 1-35711

       Dear Mr. Benfield:

              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 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 31, 2019

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       Segment Results, page 52

   1.                                                   We note the your
disclosure of Adjusted EBIDTA for the wholesale and retail
                                                        segments on pages 53
and 55 and the reconcilation of segment Adjusted EBITDA to
                                                        consolidated Adjusted
EBITDA on page 58. It appears that segment Adjusted
                                                        EBITDA represents
segment operating income disclosed in Note 21 to the financial
                                                        statements. Please
revise your disclosure on pages 53 and 55 to present operating income
                                                        of the segments.
 Jonathan Benfield
FirstName  LastNameJonathan Benfield
CrossAmerica  Partners LP
Comapany
July       NameCrossAmerica Partners LP
     28, 2020
July 28,
Page  2 2020 Page 2
FirstName LastName
Item 8. Financial Statements
Consolidated Statements of Income, page 71

2.       Please tell us how you account for your investment in CST Fuel Supply
referencing
         authoritative literature that supports your accounting treatment.
Please also tell us your
         consideration of providing CST Fuel Supply financial statements
pursuant to Rule 3-09 of
         Regulation S-X.
Form 8-K filed February 26, 2020

Exhibit 99.2, page 4

3.       Reference is made to your tabular disclosures of non-GAAP financial
information. Please
         present the most directly comparable GAAP measures with equal or
greater prominence
         in future filings. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and
Question 102.10 of
         the Division of Corporation Finance's Compliance and Disclosure
Interpretations for
         NonGAAP Financial Measures.
Exhibit 99.2, page 8

4.       Reference is made to your disclosure of 2020 Adjusted EBITDA and
Distributable Cash
         Flow guidance. In future filings, please present a reconciliation (by
schedule or other
         clearly understandable method), which shall be quantitative, to the
extent available
         without unreasonable efforts, of the differences between the non-GAAP
financial measure
         disclosed with the most directly comparable financial measure or
measures calculated and
         presented in accordance with GAAP. Refer to Item 10(e)(1)(i)(B) of
Regulation S-K.
Form 10-Q for the Quarterly Period Ended March 31, 2020

Item 1. Financial Statements
Note 11. Commitments and Contingengies
Environmental Matters, page 16

5.       We note you do not recognize environmental liabilities and
indemnification assets related
         to contamination at sites contributed to the partnership in connection
with your IPO and
         not assigned to you, and with respect to known contamination at sites
transferred to you
         which are indemnified by Circle K. Please tell us what authoritative
accounting guidance
         you applied (or applied by analogy) when determining that such
obligations and
         indemnifications assets should not be recorded on the balance sheet.
       In closing, 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.
 Jonathan Benfield
CrossAmerica Partners LP
July 28, 2020
Page 3

      You may contact Adam Phippen at (202) 551-3336 or Bill Thompson at (202)
551-
3344 with any questions.



FirstName LastNameJonathan Benfield                    Sincerely,
Comapany NameCrossAmerica Partners LP
                                                       Division of Corporation
Finance
July 28, 2020 Page 3                                   Office of Trade &
Services
FirstName LastName