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September 19, 2023
Brian DelGhiaccio
Executive Vice President, Chief Financial Officer
Republic Services, Inc.
18500 North Allied Way
Phoenix, Arizona 85054
Re:Republic Services, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 23, 2023
Form 8-K filed July 31, 2023
File No. 001-14267
Dear Brian DelGhiaccio:
            We have limited our review of your filing to the financial statements and related
disclosures 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 Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Reportable Segments, page 43
1.We note you present segment measures of Gross Adjusted EBITDA and Net Adjusted
EBITDA.  Considering comment 2 below, please revise to disclose the single measure of
segment profit or loss for each reportable segment.  Note that disclosure of additional
segment performance measures would be considered non-GAAP measures that are subject
to the provisions of Item 10(e) of Regulation S-K.  Refer to questions 104.01 through
104.06 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations
and revise to provide the disclosures required by Item 10(e) of Regulation S-K, as
necessary.

 FirstName LastNameBrian DelGhiaccio
 Comapany NameRepublic Services, Inc.
 September 19, 2023 Page 2
 FirstName LastName
Brian DelGhiaccio
Republic Services, Inc.
September 19, 2023
Page 2
Notes to Consolidated Financial Statements
Note 15. Segment Reporting, page 105
2.We note your presentation of Gross Adjusted EBITDA and Net Adjusted EBITDA on an
individual segment basis and on a combined basis for Groups 1 and 2.  We further note
disclosure on page 106, regarding your calculation of EBITDA and Adjusted EBITDA,
that this “presentation is consistent with how our chief operating decision maker reviews
results of operations to make resource allocation decisions.”  Based on this, it appears you
are presenting multiple measures of profit or loss for each reportable segment.  However,
we note that FASB ASC 280-10-50-22 requires disclosure of a single measure for each
reportable segment.  Please revise to identify and disclose the single measure of segment
profit or loss for each reportable segment that the chief operating decision maker uses for
purposes of making decisions about allocating resources to the segment and assessing its
performance.  Refer to FASB ASC 280-10-50-28, which addresses scenarios where the
chief operating decision maker uses more than one measure of a segment’s profit or loss.
3.We further note the tables presented on page 106 calculating your EBITDA, EBITDA
margin, adjusted EBITDA and adjusted EBITDA margin.  However, we note that FASB
ASC 280-10-50-30 requires reconciliation of the total of the reportable segments’
measures of profit or loss to consolidated income before income taxes and discontinued
operations, or after those items if allocated to segments.  Further to this, we note that
additional reconciliations of non-GAAP measures on a consolidated basis may be
considered non-GAAP measures.  Refer to Item 10(e)(1)(ii)(C) of Regulation S-K, which
indicates that a registrant must not present non-GAAP financial measures on the face of
the registrant's financial statements prepared in accordance with GAAP or in the
accompanying notes.  Please revise your disclosure accordingly.
Form 8-K filed July 31, 2023
Exhibit 99.1
Key Performance Metrics and Reconciliations of Certain Non-GAAP Measures, page 10
4.We note your reconciliation of adjusted EBITDA and adjusted EBITDA margin on page
11 begins with the non-GAAP measures of EBITDA and EBITDA margin.  Please revise
your reconciliation to begin with the most directly comparable GAAP measure.  Refer to
Question 102.10 of the Non-GAAP Financial Measures Compliance & Disclosure
Interpretations regarding prominence.

 FirstName LastNameBrian DelGhiaccio
 Comapany NameRepublic Services, Inc.
 September 19, 2023 Page 3
 FirstName LastName
Brian DelGhiaccio
Republic Services, Inc.
September 19, 2023
Page 3
            In closing, 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 Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Kimberly
Calder, Assistant Chief Accountant, at 202-551-3701 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation