EXRExtra Space Storage

Please revise your reconciliation in future filings to begin with net income, the most directly comparable measure, ensuring that the non-GAAP measure does not receive undue prominence. See Question 102.10 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Notes to Consolidated Financial Statements 4. Property Acquisitions and Dispositions, page 60

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We note that the amounts disclosed in the table for the number and value of OP Units issued during 2016 do not agree to the amounts disclosed in Note 13. Please tell us the actual number of OP Units issued during 2016 and the value of those units, and clarify or revise your disclosure in future filings.

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To the extent the value assigned to issued OP Units varies significantly, please tell us the reason for such variances.

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We note you provide certain non-GAAP same-store outlook numbers. In future Form 8- K 2.02 filings, please follow the guidance in C&DI Question 102.10 and provide the reconciliations required by Item 10(e)(1)(i) of Regulation S-K.

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We note that your reconciliation to Funds from operations attributable to common stockholders begins with Net income attributable to common stockholders. However, the reconciliation adds back income allocated to Operating Partnership noncontrolling interests. It appears that your FFO measure represents FFO on a company-wide basis.

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Please clarify and/or revise your presentation and labeling of the measure in future filings to adequately reflect what is being presented.

Extra Space Storage Inc. (the "Company," "we," "us" and "our") submits this letter in response to the Staff’s comment letter dated August 8, 2016. For your convenience, we have set forth the Staff’s comment and the Company’s response for each item below. The Company acknowledges the following in regard to its filings: The Company is responsible for the adequacy and accuracy of the disclosure in its filings; Staff comments or changes to disclosures 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

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federal securities laws of the United States. Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations We note that your reconciliation to Funds from operations attributable to common stockholders begins with Net income attributable to common stockholders. However, the reconciliation adds back income allocated to Operating Partnership noncontrolling interests. It appears that your FFO measure represents FFO on a company-wide basis. Please clarify and/or revise your presentation and labeling of the measure in future filings to adequately reflect what is being presented. We acknowledge the Staff’s comment and confirm that to more clearly define the FFO measure, we will relabel the total line to be “Funds from operations attributable to common stockholders and unit holders.” Please tell us how you have met all the disclosure requirements of Item 10(e) of Regulation S-K with regard to your disclosure of same-store net operating income. This comment should also be applied to the same-store presentation within your quarterly earnings release. We acknowledge the Staff’s comment and confirm that in future filings, we will update the disclosures, including by providing reconciliation of same-store net operating income to the most directly comparable GAAP measure, to comply with the disclosures required by Item 10(e) of Regulation S-K. We note that in your quarterly earnings release you focus on key non-GAAP financial measures more prominently than GAAP measures, which is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016 (specifically Question 102.10). Please review this guidance when preparing your next earnings release. We acknowledge the Staff’s comment and confirm that we will review the updated Compliance and Disclosure Interpretations issued on May 17, 2016 (including specifically Question 102.10) and update our disclosures accordingly in preparing our future earnings releases.

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Please tell us how you have met all the disclosure requirements of Item 10(e) of Regulation S-K with regard to your disclosure of same-store net operating income. This comment should also be applied to the same-store presentation within your quarterly earnings release.

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We note that in your quarterly earnings release you focus on key non-GAAP financial measures more prominently than GAAP measures, which is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016 (specifically Question 102.10). Please review this guidance when preparing your next earnings release.

See the reply above.