SEC Comment Letter for WASTE MANAGEMENT INC (WM) (CIK 0000823768) (WM) — May 4, 2012
WASTE MANAGEMENT INC (WM) (CIK 0000823768)
Date: May 4, 2012 · CIK: 0000823768 · Accession: 0000000000-12-023238
AI Filing Summary & Sentiment
Referenced dates: March 28, 2012
Letter
May 3, 2012 Via E-mail Mr. Steven C. Preston Executive Vice President – Finance, Recycling & Energy Services Waste Management, Inc. 1001 Fannin Street, Suite 4000 Houston, TX 77002 Re: Waste Management, Inc. Form 10-K Filed February 16, 2012 File No. 1-12154
Dear Mr. Preston: We have reviewed your response dated Apr il 25, 2012 and have the following comments. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-K for the year ended December 31, 2011
21. Segment and Related Information, page 130
1. We have read your response to comment 6 in our letter dated March 28, 2012. Please revise future filings to clarif y that Oakleaf is an operating segment but does not meet the criteria to be presented as a separate reportable segment. Form 10-Q for the period ended March 31, 2012
Management’s Discussion and Analysis, page 33
2. You disclose on page 40 that the Company has offered price concessions to retain municipal work in many instances due to competition and the increasing difficulty in retaining customers and winning new contracts at current aver age rates. To the extent
Mr. Steven C. Preston Waste Management, Inc. May 3, 2012 Page 2
material in future filings, please quantify th e impact of such concessions and describe your use of them in more detail. In future filings, please quantify the amount of revenue in each period from residential se rvices vs. commercial and indus trial. This appears to be useful information to investors as evidenced by the discussion of downward pressure on revenue growth in the residential sector included in the most recent Forms 10-Q and 10- K. You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3355 if you have questions regarding comments on the financia l statements and related matters.
Sincerely,
/s/ Terence O’Brien
Terence O’Brien Branch Chief
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May 3, 2012
Via E-mail
Mr. Steven C. Preston Executive Vice President – Finance, Recycling & Energy Services Waste Management, Inc. 1001 Fannin Street, Suite 4000 Houston, TX 77002
Re: Waste Management, Inc.
Form 10-K
Filed February 16, 2012 File No. 1-12154
Dear Mr. Preston:
We have reviewed your response dated Apr il 25, 2012 and have the following comments.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10-K for the year ended December 31, 2011
21. Segment and Related Information, page 130
1. We have read your response to comment 6 in our letter dated March 28, 2012. Please
revise future filings to clarif y that Oakleaf is an operating segment but does not meet the
criteria to be presented as a separate reportable segment.
Form 10-Q for the period ended March 31, 2012
Management’s Discussion and Analysis, page 33
2. You disclose on page 40 that the Company has offered price concessions to retain
municipal work in many instances due to competition and the increasing difficulty in
retaining customers and winning new contracts at current aver age rates. To the extent
Mr. Steven C. Preston Waste Management, Inc. May 3, 2012 Page 2
material in future filings, please quantify th e impact of such concessions and describe
your use of them in more detail. In future filings, please quantify the amount of revenue
in each period from residential se rvices vs. commercial and indus trial. This appears to be
useful information to investors as evidenced by the discussion of downward pressure on
revenue growth in the residential sector included in the most recent Forms 10-Q and 10-
K. You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3355 if you have
questions regarding comments on the financia l statements and related matters.
Sincerely,
/s/ Terence O’Brien
Terence O’Brien Branch Chief