WMWaste Management

Please amend your filing to include a revised management’s report on internal control over financial reporting with a statement as to whether or not your internal control over financial reporting is effective. Refer to Item 308(a) of Regulation S-K.

Amended Item 9A Controls and Procedures. Management’s Report on Internal Control Over Financial Reporting, page 127

The Company will include the following statement in Management’s Report on Internal Control Over Financial Reporting within a Form 10-K/A for the year ended December 31, 2021:

“Management of the Company assessed the effectiveness of our internal control over financial reporting as of December 31, 2021 based on the 2013 framework in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (the COSO criteria).

Rest of the answer

Based on this assessment, management has concluded that our internal control over financial reporting was effective as of December 31, 2021.”

The Company intends to file the amendment to the Form 10-K on March 29, 2022.

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The Company acknowledges that:

● the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

● Staff comments or changes to disclosure 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 federal securities laws of the United States.

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