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United States securities and exchange commission logo





                              September 14, 2021

       Adam Satterfield
       Chief Financial Officer
       Old Dominion Freight Line, Inc.
       500 Old Dominion Way
       Thomasville , NC 27360

                                                        Re: Old Dominion
Freight Line, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 24,
2021
                                                            File No. 000-19582

       Dear Mr. Satterfield:

              We have reviewed your filing 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, 2020

       Risk Factors, page 6

   1.                                                   Disclose the material
effects of transition risks related to climate change that may affect
                                                        your business,
financial condition, and results of operations, such as policy and regulatory
                                                        changes that could
impose operational and compliance burdens, market trends that may
                                                        alter business
opportunities, credit risks, or technological changes.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       20

   2.                                                   If material, discuss
the significant physical effects of climate change on your operations
                                                        and results. This
disclosure may include the following:
                                                            quantification of
material weather-related damages to your property or operations;
                                                            and
                                                            any weather-related
impacts on the cost or availability of insurance.
 Adam Satterfield
Old Dominion Freight Line, Inc.
September 14, 2021
Page 2
3.       If material, please quantify past capital expenditures for
climate-related projects.
4.       Quantify any material increased compliance costs related to climate
change.
5.       If applicable and material, provide disclosure about any purchase or
sale of carbon credits
         or offsets and any material effects on your business, financial
condition, and results of
         operations.
        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 Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding
comments.



FirstName LastNameAdam Satterfield                              Sincerely,
Comapany NameOld Dominion Freight Line, Inc.
                                                                Division of
Corporation Finance
September 14, 2021 Page 2                                       Office of
Energy & Transportation
FirstName LastName
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