October 2, 2019

Patrick Dovigi
President and Chief Executive Officer
GFL Environmental Holdings Inc.
100 New Park Place, Suite 500
Vaughan, Ontario, Canada L4K 0H9

       Re: GFL Environmental Holdings Inc.
           Amendment No. 3 to Registration Statement on Form F-1
           Filed September 30, 2019
           File No. 333-232731

Dear Mr. Dovigi:

      We have reviewed your amended registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our September
27, 2019.

Form F-1/A Filed September 30, 2019

Financial Statements
GFL Environmental Holdings, Inc., page F-2

1.     We note your response to comment 6. The disclosures that you refer to
along with the
       interest and other finance costs, deferred purchase consideration, loss
(gain) on sale of
       property, plant and equipment, loss (gain) on foreign exchange and other
income line
       items on the face of your statements of operations do not appear to
provide insight about
       the nature of all of your expenses. For example for the seven months
ended December 31,
       2018, the disclosures you refer to as well as the income statement line
items noted above
       appear to only address the nature of approximately 60% of your total
expenses. In this
       regard, please provide a breakdown of total expenses based on the nature
of
 Patrick Dovigi
GFL Environmental Holdings Inc.
October 2, 2019
Page 2
      expenses. Refer to IAS 1.104 and 105.
       You may contact Nudrat Salik at 202-551-3692 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Sergio Chinos at 202-551-7844 or Asia Timmons-Pierce at 202-551-3754 with any
other
questions.



                                                         Sincerely,
FirstName LastNamePatrick Dovigi
                                                         Division of
Corporation Finance
Comapany NameGFL Environmental Holdings Inc.
                                                         Office of Energy &
Transportation
October 2, 2019 Page 2
cc:       Ryan Bekkerus
FirstName LastName