August 12, 2019 Scott A. Cottrill Executive Vice President, Chief Financial Officer, and Secretary Advanced Drainage Systems, Inc. 4640 Trueman Boulevard Hilliard, OH 43026 Re: Advanced Drainage Systems, Inc. Registration Statement on Form S-3 Filed August 1, 2019 File No. 333-232958 Dear Mr. Cottrill: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction