Acadia
Realty Trust
1311
Mamaroneck Avenue, Suite 260
White
Plains, NY 10605
December
17, 2007
VIA
EDGAR
U.S.
Securities and Exchange Commission
100
F
Street, N.E.
Washington,
D.C. 20549
| Re: | Acadia Realty Trust |
| Form 10-K for the year ended December 31, 2006 | |
| File No. 001-12002 |
Ladies
and Gentlemen,
In
connection with responding to a comment from the Staff of the Division of
Corporate Finance regarding the above-referenced filing, Acadia Realty Trust
hereby acknowledges that:
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§
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it
is responsible for the adequacy and accuracy of the disclosure in
the
filing;
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§
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staff
comments or changes to disclosure in response to staff comments do
not
foreclose the Commission from taking any action with respect to the
filings; and
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§
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it
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.
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Please
direct any questions with respect to the foregoing to my attention at (914)
288-8138.
Sincerely,
/s/
Michael Nelsen
Michael
Nelsen
Senior
Vice President and
Chief
Financial Officer