February 26, 2020

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. 8 to Registration Statement on Form F-1
           February 18, 2020
           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 [Month day,
year] letter.

Form F-1/A Filed February 25, 2020

Capitalization, page 74

1.     Your response to comment 3 in your letter dated February 3, 2020
indicated that you
       expected the reduction to interest expense as a result of using proceeds
of the offerings to
       repay debt to not be material to investors though at that time you did
not know the size of
       the offerings. Given that your new disclosures indicate you now intend
to use all of the net
       proceeds of the offerings to repay approximately 46% of your debt,
please help us further
       understand how you determined that pro forma financial information
showing the
       reduction in interest expense would not be material. In this regard, we
note that 2019
       interest and financing costs were nearly 90% of your pre-tax loss. Given
that the pro
       forma Statement of Operations adjustments only impact interest/financing
expense and
 Patrick Dovigi
GFL Environmental Holdings Inc.
February 26, 2020
Page 2
      income tax expense, a narrative description of the pro forma effects of
the transaction on
      the impacted 2019 Statements of Operations line items and EPS may be
furnished in lieu
      of a full 2019 pro forma Statement of Operations. See Article 11-01(a)(8)
and 11-02(b)(1)
      of Regulation S-X.
       You may contact Nudrat Salik at 202-551-2692 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Asia Timmons-Pierce at 202-551-3754 or Jay Ingram at 202-551-3397 with any
other questions.



                                                           Sincerely,
FirstName LastNamePatrick Dovigi
                                                           Division of
Corporation Finance
Comapany NameGFL Environmental Holdings Inc.
                                                           Office of
Manufacturing
February 26, 2020 Page 2
cc:       Ryan Bekkerus
FirstName LastName