SecProbe.io

December 9, 2011
 Via E-mail

Mr. Thomas J. Cowee Chief Financial Officer Progressive Waste Solutions Ltd. 400 Applewood Crescent, 2nd Floor Vaughan, Ontario L4K 0C3 Canada
RE: Progressive Waste Solutions Ltd.
Form 40-F for Year e nded December 31, 2010
Filed March 31, 2011
  File No. 1-34370

Dear Mr. Cowee:
 We have reviewed your filings and have th e following comment.  In our comment, we
may ask you to provide us with informati on 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 comment applies to your facts a nd circumstances, please tell us why in your
response.

After reviewing the information you provide in  response to this comment, we may have
additional comments.     Form 40-F for Year ended December 31, 2010

 General

 1. General instruction B(3) of the Form 40-F requires you to file audited annual financial
statements and accompanying management's disc ussion and analysis under the cover of the
Form 40-F.  In future filings, please provi de the audited financial statements and
accompanying management’s discussion and analysis in your Form 40-F rather than incorporating by reference thes e items into your Form 40-F.  Alternatively, you may file
these items as exhibits to the Form 40-F.

Mr. Thomas J. Cowee Progressive Waste Solutions Ltd. December 9, 2011 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
 In responding to our comment, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

If you have any questions regarding this comm ent, please direct them to Nudrat Salik,
Staff Accountant, at (202) 551-3692 or, in her absence, to Jeanne Baker, Assistant Chief
Accountant, at (202) 551-3691.         S i n c e r e l y ,          / s /  R u f u s  D e c k e r

Rufus Decker
       Accounting Branch Chief