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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.
 Brian DelGhiaccio
FirstName LastNameBrian   DelGhiaccio
Republic Services, Inc.
Comapany 19,
September NameRepublic
              2023       Services, Inc.
September
Page 2    19, 2023 Page 2
FirstName LastName
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.
 Brian DelGhiaccio
FirstName LastNameBrian   DelGhiaccio
Republic Services, Inc.
Comapany 19,
September NameRepublic
              2023       Services, Inc.
September
Page 3    19, 2023 Page 3
FirstName LastName
       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