<PAGE>
PROSKAUER ROSE LLP
1585 Broadway
New York, NY 10036
(212) 969-3000
August 15, 1997
VIA EDGAR
Evan Calio, Esq.
U.S. Securities and Exchange Commission
Division of Corporation Finance
Department of Natural Resources
450 Fifth Street, NW
Washington, DC 20549
Re: American Disposal Services, Inc.
Post-Effective Amendment No. 1 to the
Registration Statement Filed August 8, 1997
FILE NO. 333-28491
-------------------------------------------
Dear Mr. Calio:
Pursuant to Rule 477 of the Securities Act of 1933 (the "Securities
Act"), on behalf of our client American Disposal Services, Inc. (the
"Company"), I hereby request the withdrawal of the Post-Effective Amendment
No.1 to the Registration Statement of the Company (the "Amendment") filed
with the Securities and Exchange Commission (the "Commission") on August 8,
1997. The Amendment is being withdrawn to comply with the Commission's
Release No. 33-7431 relating to the conversion to a shorter Securities Act
form.
If you have any questions or comments, please feel free to call either
me (212-969-3514) or Stephen W. Rubin (212-969-3330) of this firm.
Very truly yours,
/s/ GREGORY T. WALTERS
Gregory T. Walters
