SecProbe.io

January 8, 2015

Via E -mail
Mr. Ian Kids on
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
Filed March 28 , 2014
File No. 1-34370

Dear Mr. Kidson:

We have reviewed your response dated December 23, 2014, and have the following
comment s.

Please respond to this letter within ten 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 s apply  to your facts and circumstances, please tell us why in your response.

After reviewing the information you prov ide in response to these comment s, we may
have  additional comments.

Form 40 -F for the year ended December 31, 2013

Exhibit 99.2 MD&A

Critical Accounting Estimates, page 41

1. Thank you for your response to comment 1 in your letter dated December 23, 2014.  We
have the following additional comments:
 Please provide us with an analysis of how you have adjusted the “probability
weighted expected cash flows” to reflect the inherent uncertainty of contractual award
in the most recent calculations of the U.S . northeast reporting unit’s fair value,
including the test completed on April 30, 2013, and your latest calculation.
 Please provide us with a description of material events occurring since 2013,
including the reissuance of the RFP by DSNY and the developm ents discussed briefly
in your Form 6 -K filed on October 30, 2014, where you state, “certain developments,
including current local support for the development of the operating location
necessary to execute the New York City long -term contract, have made th e likelihood

Mr. Ian Kid son
Progressive Waste Solutions Ltd .
January 8, 2015
Page 2

 of being awarded the contract indeterminate at this time.”  Tell us the impact these
events have had on your assumptions and testing methodology for your most recent
test.
 Please describe for us the significant assumptions, methods, and result s for the Step 1
test of impairment you expected to complete on or before December 31, 2014, and the
Step 2 test, to the extent relevant and available.
 Tell us the relevant information you considered in developing your assumptions, such
as information on c ompetitors, the sites or vendors capable of servicing the
unawarded portion of the contract, and the existence of any Letter of Intent,
Memorandum of Understanding or similar agreement with the City of New York.
 Based on the magnitude of the assumed cash f lows from the New York City long -
term contract, describe for us your current understanding of the potential range of
magnitude of an impairment loss that would result from the inability to secure a
contract with the expect terms.

You may contact Jenn Do at (202) 551-3743  or me at (202) 551 -3355  if you have
questions regarding comments on the financial statements and related matters.  Please contact
Sherry Haywood  at (202) 551 -3345, or Era Anagnosti a t (202) 551 -3369, with any other
questions

Sincerely,

 /s/ Terence O ’Brien

Terence O’Brien
Branch Chief