SecProbe.io

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August 30, 2005

Mail Stop 7010

By U.S. Mail and facsimile to (602) 423-9424

Steven M. Helm, Esq.
Executive Vice President and General Counsel
Allied Waste Industries, Inc.
15880 North Greenway-Hayden Loop, Suite 100
Scottsdale, Arizona 85260

Re: 	Allied Waste Industries, Inc.
	Amendment No. 1 to Registration Statement on Form S-4
Filed August 16, 2005
	File No. 333-126239

Dear Mr. Helm:

      We have limited our review of your filing to those issues we
have addressed in our comments.  We welcome any questions you may
have about our comments or any other aspect of our review.  Feel
free
to call us at the telephone numbers listed at the end of this
letter.

Exhibits
Exhibit 5.1, Opinion of Latham & Watkins LLP

1. Please submit a revised legality opinion opining that all
guarantees, including those by entities other than the Identified
Guarantors, are binding obligations.  In addition, we note your
counsel`s assumption that "each Guarantor is duly organized,
validly
existing, and in good standing under the laws of its jurisdiction
of
organization" for guarantors incorporated in states other than New
York and Delaware.  Please submit a revised legality opinion that
does not contain this assumption.  Alternatively, we will not
object
if counsel obtains local corporate law opinions necessary to
support
its opinion, replaces the assumptions in the first paragraph of
page
3 with a statement that it is relying on those opinions, and files
the local opinions as exhibits to the registration statement.
      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date

      Please contact Matt Franker, Staff Attorney, at (202) 551-
3749
with any questions.  Alternatively, you may contact me at (202)
551-
3767.

Sincerely,

Jennifer Hardy
Branch Chief

cc:	Gregory A. Ezring, Esq. (via facsimile 212/751-4864)
      Latham & Watkins LLP
      885 Third Avenue, Suite 1000
      New York, New York 10022
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Steven M. Helm, Esq.
Allied Waste Industries, Inc.
August 30, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

           DIVISION OF
CORPORATION FINANCE

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