September 8, 2025

Mary Anne Whitney
Chief Financial Officer
Waste Connections, Inc.
6220 Hwy 7, Suite 600
Woodbridge, Ontario L4H 4G3
Canada

       Re: Waste Connections, Inc.
           Form 10-K for the Fiscal Year ended December 31, 2024
           Filed February 13, 2025
           File No. 001-34370
Dear Mary Anne Whitney:

       We have reviewed your filing and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Financial Statements
Note 13 - Commitments and Contingencies, page 122
Legal Proceedings, page 123

1.     We note that you identify six matters of litigation on pages 123-129
that could have a
       material adverse effect on your business, financial condition, results
of operations or
       cash flows, although for each you state that you are "not able to
determine the
       likelihood of any outcome." We also note that you include various risk
factors
       concerning these matters under Item 1A. For example, on page 35, you
reference
       environmental problems and state that these "could result in substantial
remediation
       costs, regulatory enforcement actions and related fines or potential
litigation," and on
       page 46, you reference litigation and governmental proceedings and state
"the
       possible outcomes or resolutions to these matters could include adverse
judgments or
       settlements, either of which could require substantial payments,
adversely affecting
       our consolidated financial condition, results of operations and cash
flows."
 September 8, 2025
Page 2


       Please expand your disclosures to clarify the extent of any accounting
that has
       been reflected in your financial statements for such matters, to include
the extent of
       any accruals that you have made and the periods impacted, also to
specify the range of
       reasonably possible additional loss for each matter, or to clarify if
such an estimate is
       not possible in which case also specify the amounts of any claims for
damages and
       penalties, where such claims have been quantified by the counterparties.

       Given the significant level of estimation uncertainty that appears to be
characteristic
       of the difficulty you express in understanding the prospects for
resolution, it appears
       that you should also expand your disclosures in (i) MD&A to include
qualitative and
       quantitative information regarding the estimation uncertainty and the
impact the
       critical accounting estimate has had, or is reasonably likely to have,
on your financial
       condition and results of operations, to address the critical accounting
estimate
       disclosure requirements in Item 303(b)(3) of Regulation S-K, and (ii)
Note 3 to your
       financial statements to describe the policy that you have formulated,
based on the
       guidance in FASB ASC 450-20, as to the accounting and disclosures
related to loss
       contingencies, to comply with FASB ASC 235-10-50-1.


        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 Lily Dang at 202-551-3867 or Robert Babula at
202-551-3339 if you
have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation