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corresp

Andrews

    111 Congress Avenue, Suite 1700

Austin, Texas 78701

512.320.9200 Phone

512.320.9292 Fax

andrewskurth.com

Kinloch Gill

512 320.9209 Phone

512 542.5206 Fax

kinlochgill@andrewskurth.com

ATTORNEYS    KURTH
  LLP

November 30, 2005

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W., Mail Stop 7010

Washington, D.C. 20549

         Re:

    WCA Waste Corporation

PRE 14A filed November 18, 2005

File No. 000-50808

Ladies and Gentlemen:

     WCA Waste Corporation, a Delaware corporation (the “Company”) has received your letter
dated November 30, 2005 (your “Comment Letter”) addressed to Tom J. Fatjo, III, Senior Vice
President—Finance and Secretary of the Company, pursuant to which you provided a comment from the
staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on the
preliminary Schedule 14A filed November 18, 2005 (the “Proxy”). We have set forth below on
behalf of the Company the Company’s response to such comment. For your convenience, the comment
contained in your Comment Letter is set forth verbatim in the italicized paragraphs below. The
Company’s response appears in the plain text following such comment.

PRE 14A filed November 18, 2005

    1.

    We note that you are seeking approval of an amendment to the articles of
incorporation in order to increase the authorized shares of common stock available for
issuance. Please tell us if this increase in shares is necessary in order to complete
any particular acquisition. If an increase in authorized common shares is necessary to
complete an acquisition contemplated at this time, you should revise the proxy
statement to include the information required by Item 14 of Schedule 14A. See also
Note A to Schedule 14A. In this regard, we note disclosure in the proxy statement on
page seven with respect to recent acquisitions in which you have issued common shares
as consideration, as well as the statement that additional common shares will provide
you with flexibility in financing your acquisition strategy. Additionally, we note
your Form 8-K filed on November 8, 2005 discloses that you are in “active discussions”
with companies

Securities and Exchange Commission

Division of Corporation Finance

November 30, 2005

Page 2

    regarding acquisitions, refers to an “acquisition pipeline,” and states that you
plan to finance acquisitions through a combination of borrowings and the issuance of
common stock.

    The proposed increase in shares is not necessary in order to
complete a particular acquisition. Rather, the Company included the
disclosure to inform stockholders that in prior transactions shares
had been issued and that in the future shares may be issued in
connection with acquisitions.

     In addition, as requested in the Comment Letter, the Company acknowledges the following:

     1. The Company is responsible for the adequacy and accuracy of the disclosure in the Proxy.

     2. Staff comments or changes to disclosure in response to Staff comments do not foreclose the
SEC from taking any action with respect to the Proxy.

     3. The Company may not assert Staff comments as a defense in any proceeding initiated by the
SEC or any person under the federal securities laws of the United States.

     If you have any further comments, please contact the undersigned by telephone at (512)
320-9209 or by fax at (512) 320-9292. Thank you in advance for your prompt consideration of the
response in this letter.

    Very truly yours,

    /s/ Kinloch Gill III

    Kinloch Gill III

    cc:

    Tom J. Fatjo, III