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57 0 obj << An individual commercial customer typically generates substantially more MSW than a residential customer. The proposed acquisition would reduce from three to two the number of significant competitors for the disposal of MSW in the Anderson, IN area. /Annots [] >> /Rotate 0 5. ( << >> /Parent 8 0 R For the Court's convenience, Florida has attached a redline, as Exhibit A, showing changes from the First Amended Complaint. /MediaBox [0 0 612 792] /Type /Page /Parent 9 0 R /Contents [378 0 R 379 0 R 380 0 R] /MediaBox [0 0 612 792] After the acquisition, Allied would control over 40 percent and two firms would control over 65 percent of the small container commercial waste hauling market, which has annual revenues of about $5 million. The global coronavirus pandemic threatens to disrupt the Presidential 4. 62 0 obj %%EOF 45. 36 0 obj endobj Small Container Commercial Waste Collection Service. 4 0 obj Jurisdiction is conferred on this Court by Chapters 26, 34, 86.011. >> /Rotate 0 /CropBox [0 0 612 792] provide preliminary and permanent injunctive relief pursuant to Rules 57 and 64 of the Federal Rules of Civil Procedure and 28 U.S.C. << endobj COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Introduction 1. Defendants because the Amended Complaint seeks injunctive relief only for these Counts, to which qualified immunity does not apply. 31 0 obj 29. /CropBox [0 0 612 792] /Contents [122 0 R 123 0 R 124 0 R] >> << /CropBox [0 0 612 792] /Resources 233 0 R /Type /Page /CropBox [0 0 612 792] - All Rights Reserved, Community Advocacy & Social Responsibility, Traditional Contract Principles Impacting Enforcement of Noncompete Agreements in Florida. If the major roll-off competitor in a market likewise precludes significant competition through the use of long-term customer contracts which automatically renew, entry by new competitors and growth from existing ones are further hindered. /Type /Page Therefore, the video continues on this topic by explaining: A suit for injunction is an extraordinary remedy for businesses and individuals alike. JURISDICTION AND VENUE 2. 0000003946 00000 n Download the PDF of the Complaint IN THIS PUBLICATION Summary Issues COVID-19 83.40 et seq. /Annots [] >> /Contents [282 0 R 283 0 R 284 0 R] << << /CropBox [0 0 612 792] %%EOF It is engaged in providing waste collection and disposal services throughout the United States. << /Annots [] 39 0 obj /Contents [278 0 R 279 0 R 280 0 R] 41. endobj 93 0 obj WEST PALM BEACH DIVISION . The county court may issue a temporary and permanent injunction where appropriate for violation of ss. In addition, a FEL or REL vehicle cannot be efficiently driven long distances without collecting significant amounts of MSW, which makes it economically impractical for a small container commercial waste collection firm to serve metropolitan areas from a distant base. endobj /CropBox [0 0 612 792] /CropBox [0 0 612 792] . 61. /Type /Page endstream endobj 29 0 obj <>stream >> Allied and Republic are two of only a few providers of waste collection or disposal services in each of the identified areas. /Parent 11 0 R Anyone who fails to dispose of MSW in an approved facility can be subject to severe civil and criminal penalties. /Rotate 0 23. /MediaBox [0 0 612 792] /CropBox [0 0 612 792] /Type /Pages Should you request a temporary injunction or push quickly for final permanent injunction. "Anderson, IN area" means the City of Anderson and Madison County, Indiana. /Type /Pages /MediaBox [0 0 612 792] After the acquisition, Allied would control over 55 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues of about $28 million. /Rotate 0 >> /Parent 8 0 R /Parent 9 0 R Although, where available, MSW can be transported to distant landfills through transfer stations using large transfer trailer trucks, the use of transfer stations adds fixed transportation and processing costs. After the acquisition, Allied would control roughly 30 percent--and two firms about 66 percent--of the New York City, NY area MSW disposal market, which has annual revenues of about $40 million. Therefore, its important to not consider it a tool for righting a wrong. The cost advantage of local landfills limits the areas where MSW can be economically transported and disposed of by haulers and creates localized markets for MSW disposal services. endobj << /Annots [] /Rotate 0 Entry would also be made more difficult by Republic's use of long-term, automatically renewing contracts for roll-off service. /Rotate 0 /Resources 377 0 R endobj After the acquisition, Republic would control about 40 percent--and three firms over 75 percent--of the small container commercial waste hauling market, which has annual revenues of about $18 million. 43 0 obj /CropBox [0 0 612 792] PDF Verified Complaint for Declaratory and Injunctive Relief << 72 0 obj endobj 30 0 obj Injunctive relief is considered an extraordinary remedy in both State and Federal court. /MediaBox [0 0 612 792] endobj 0000000556 00000 n trailer /Rotate 0 "Nashville, TN area" means the City of Nashville and Davidson, Sumner, Williamson, Rutherford, Wilson, the southeastern part of Robertson, and the eastern part of Cheatham counties, Tennessee. 37 0 obj >> /Annots [] 21. Complaint for Declaratory and Temporary and Permanent Injunctive Relief (the "Complaint"), which is incorporated herein by this reference.1 As shown in the Complaint, the HRO is null and void for failure to comply with Florida Statutes, the Jacksonville Ordinance Code, and the Rules of the Council of the City of Jacksonville. >> 45], filed on August 192021, . There may be disclosure of confidential information such as trade secrets. 3. 0000000016 00000 n Significant new entry into the disposal of MSW in the Anderson, IN and New York City, NY areas would be difficult and time-consuming. xref << This form is a Complaint for Injunctive Relief and Damages. The predictable result is the denial of the vote to untold numbers of Floridians who had planned to vote in person on Election Dayincluding those who are elderly or have health conditions and cannot get to the polls without tremendous risk, university students who are no longer present in their county of registration because their dorms have closed, and those who venture out but encounter long lines and confusion at the polls. endobj _______/s/____________________ Donna E. Patterson Deputy Assistant Attorney General, _________/s/__________________ Constance K. Robinson Director of Operations and Merger Enforcement, ________/s/___________________ J. Robert Kramer II Chief, Litigation II Section, _________/s/__________________ Willie L. Hudgins Assistant Chief, Litigation II Section, ___________/s/________________ Arthur A. Feiveson IL Bar # 3125793, __________/s/_________________ Michael K. Hammaker DC Bar # 233684, __________/s/_________________ Chinita M. Sinkler MD Bar, U.S. Department of Justice Antitrust Division, Litigation II Section 1401 H Street, NW, Suite 3000 Washington, D.C. 20530 (202) 307-0924. An official website of the United States government. 2201 a nd 2202. 7. % /S /D endobj >> Deciding Whether to Sue for Injunction, and What is the Process to /Contents [406 0 R 407 0 R 408 0 R] 39. h|VrH}Weo2)RXBr|:=%ts?mlteQG :C:+rl86#m0GcfFmMb`4&;|Xy|^Q(&Y Jf#mb!nDlpfIi QB*Mg< /Resources 393 0 R Thus, small container commercial waste collection service is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisitions under Section 7 of the Clayton Act. /MediaBox [0 0 612 792] In the Macon, GA area, the acquisition would reduce from two to one the number of significant firms that compete in the collection of small container commercial waste. endobj /MediaBox [0 0 612 792] /Rotate 0 /MediaBox [0 0 612 792] endobj /Contents [334 0 R 335 0 R 336 0 R] /Resources 289 0 R 54. PDF Florida Small Claims Rules Annotated 2020 - The Florida Bar /CropBox [0 0 612 792] 83 0 obj 51. /CropBox [0 0 612 792] endobj << >> endobj SOUTHERN DISTRICT OF FLORIDA . ( /Resources 225 0 R In order to obtain comparable operating efficiency, a new firm must achieve route density comparable to existing firms. Venue is therefore proper in this district under Section 12 of the Clayton Act, 15 U.S.C. >> endobj /Type /Pages << << endobj ;,hn \ic6rZFi+|:GsL$KGqzed8;M+"N7i~4Dr?_1hHa:`R[B%Qm*?u9Lh=?y%x8;e$AD+xx 25. /MediaBox [0 0 612 792] Rule 1.610 of the Florida Rules of Civil Procedure governs requests for temporary injunctions. Plaintiff seeks temporary, preliminary, and permanent injunctive relief pursuant to Rule 65 . PDF Complaint for Emergency Injunctive and Declaratory Relief PDF IN THE CIRCUIT COURT OF THE - Florida Attorney General /Parent 7 0 R /Resources 141 0 R The transactions likely will have the following effects, among others: 1. /Type /Page >> The proposed transactions, identified below, would lessen competition substantially in waste collection and/or disposal services: (1) Allied's acquisition of hauling assets in Albany, New York; (2) Allied's acquisition of hauling assets in Augusta, Georgia; (3) Allied's acquisition of hauling assets in Memphis, Nashville and Clarksville, Tennessee; (4) Allied's acquisition of disposal assets in New York, New York; (5) Allied's acquisition of hauling assets in Norfolk, Virginia; (6) Allied's acquisition of hauling assets in Okaloosa, Escambia and Santa Rosa counties, Florida ("Gulf Coast, Florida"); (7) Republic's acquisition of disposal assets in Anderson, Indiana; (8) Republic's acquisition of hauling assets in Columbus, Ohio; (9) Republic's acquisition of hauling assets in Lakeland, Florida; (10) Republic's acquisition of hauling assets in Louisville, Kentucky and Sellersburg, Indiana; (11) Republic's acquisition of hauling and disposal assets in Macon, Georgia; and (12) Republic's acquisition of hauling assets in Monmouth, Burlington and Camden counties, New Jersey. endobj /CropBox [0 0 612 792] : 01-42230-BKC-AJC . /MediaBox [0 0 612 792] >> /Resources 237 0 R 0000003404 00000 n /Type /Page << << PDF United States District Court Northern District of Florida Pensacola ( The acquisition would reduce from three to two the number of significant firms that compete in the collection of small container commercial waste in the Burlington and Camden Counties, NJ area. << /Annots [] /Type /Page &%e2#4DqB#K.tt.GYeMbN!uiW-C`oIynF,fD5c&a8|A!y%?ci6Ywo`aPT=Yz0Id endobj /Kids [85 0 R 86 0 R 87 0 R 88 0 R 89 0 R 90 0 R 91 0 R 92 0 R 93 0 R] prices charged by roll-off waste collection firms in the Macon, GA area market will likely increase. % /Parent 13 0 R /Type /Page After the acquisition, Republic would control over 50 percent--and two firms about 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $22 million. 18. 0000001563 00000 n IV. 54 0 obj << /Annots [] relief pursuant to Chapter 86, Florida Statutes. >> << PDF COMPLAINT FOR PERMANENT INJUNCTION - United States Department of Justice /Parent 4 0 R Statutes & Constitution :View Statutes : Online Sunshine /Parent 9 0 R >> /Resources 353 0 R endobj 0000001469 00000 n /Contents [346 0 R 347 0 R 348 0 R] << /Type /Page >> Permit restrictions often impose severe limitations on the type and amount of waste that can be disposed of at landfills. <> /Type /Page /Type /Page endobj endobj ( PDF In the Supreme Court of Florida Case No.: Sc11- Third District Case No 2 0 obj ( 23 0 obj <> endobj 28 0 obj <>/Filter/FlateDecode/ID[<2A277BAC2070266E6BF2C2060AD46B2B>]/Index[23 11]/Info 22 0 R/Length 49/Prev 24323/Root 24 0 R/Size 34/Type/XRef/W[1 2 1]>>stream 52. /Type /Page /Count 10 >> >> 0000001852 00000 n A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. /Rotate 0 /Contents [254 0 R 255 0 R 256 0 R] << >> 22 and 28 U.S.C. The next step is careful preparation before the temporary injunction hearing. /Parent 10 0 R << /Contents [154 0 R 155 0 R 156 0 R] /Annots [] ( 48 0 obj ( /Parent 10 0 R MSW generated by residential customers, on the other hand, is often collected by either local governments or by private haulers pursuant to contracts bid by, or franchises granted by, municipal authorities. 20. 31 0 obj <>stream << stream 67. >> /Contents [190 0 R 191 0 R 192 0 R] /Parent 11 0 R /Parent 9 0 R endobj PDF Complaint for Injunctive Relief Representatives /Kids [75 0 R 76 0 R 77 0 R 78 0 R 79 0 R 80 0 R 81 0 R 82 0 R 83 0 R 84 0 R] (PC) Carroll v. Vallejo Police Department, et al., No. 1:2023cv00004 /Rotate 0 Markets in which the HHI is between 1000 and 1800 points are considered to be moderately concentrated, and those in which the HHI is in excess of 1800 points are considered to be highly concentrated. /Parent 12 0 R K.A%aut\@Uaa[pVWnOe endobj /CropBox [0 0 612 792] xb```c``b`f`0gg@ ~G@|*{jd`q%T3e83:! @`HsXD|",e0`A 21. /Annots [] /Parent 7 0 R endobj Universities have sent students home, people are remaining in quarantine, poll workers are dropping out, and Supervisors of Elections have closed or moved 112 polling places in 22 counties, in many cases less than a week before the election. Annotations: Subsection (b) of the rule extends the Small Claims Rules to all claims for money or property, even when expressed or coupled with a claim for equitable relief. 48. /Rotate 0 /Parent 7 0 R "Monmouth County, NJ area"means the City of Marlboro and Monmouth County, New Jersey. /MediaBox [0 0 612 792] Is there any vagueness, or is everything extremely clear? The acquisitions by Allied and Republic would remove a significant competitor in small container commercial waste collection service, roll-off waste collection service, and/or the disposal of MSW, in already highly concentrated and difficult-to-enter markets. 18. /CropBox [0 0 612 792] After the acquisition, Allied would control roughly 69 percent--and two firms over 90 percent--of the small container commercial waste hauling market, which has annual revenues exceeding $25 million. /Resources 293 0 R The global coronavirus pandemic threatens to disrupt the Presidential Preference Primary (PPP) election in Florida, scheduled for tomorrow, March 17, 2020, and cause large-scale voter disenfranchisement falling hardest on communities of color and other historically vulnerable populations. /Annots [] /Contents [146 0 R 147 0 R 148 0 R] 24. /Annots [] >> >> /Type /Page JFIF C ( (Compl . 8. /Type /Pages In the Macon, GA area, the proposed acquisitions would result in Republic controlling more than 60 percent of the roll-off waste collection market at the same time it owns the two primary disposal options which any roll-off competitor would most likely use. /Annots [] /Annots [] << /Contents [198 0 R 199 0 R 200 0 R] /CreationDate (D:20220824140929-04'00') << /Rotate 0 "Burlington and Camden Counties, NJ area" means Burlington and Camden counties, New Jersey. 27 0 obj /Parent 7 0 R /Annots [] Allied is the nation's second largest waste hauling and disposal company. Republic is engaged in providing waste collection and disposal services throughout the United States. ( For a number of reasons, landfills may not be located close to where the waste is generated. /CropBox [0 0 612 792] ]Wx C1>*yvL#uR$=I$$WJQg%=ElRS3DE27y1 G. >> /MediaBox [0 0 612 792] /Contents [250 0 R 251 0 R 252 0 R] Complaint for Emergency Injunctive Relief in Florida Primary /Annots [] 1 0 obj /CropBox [0 0 612 792] /Filter /FlateDecode M`5`i`F{qZ /Annots [] /Annots [] 82 0 obj /Parent 7 0 R >> /Contents [118 0 R 119 0 R 120 0 R] /Parent 14 0 R /MediaBox [0 0 612 792] (ECF No. Haulers, therefore, generally establish garages and related facilities within each major local area served. /CropBox [0 0 612 792] 55. 24 0 obj Plaintiff complains and alleges as follows: 1. /Parent 13 0 R /Contents [106 0 R 107 0 R 108 0 R] 13 0 obj /Rotate 0 /Type /Page << Plaintiff is a Florida resident, lives in Miami- Dade County, is sui juris, and qualifies of a protected class under the ADA, 42 U.S.C. /Contents [210 0 R 211 0 R 212 0 R] /Contents [390 0 R 391 0 R 392 0 R] _l {:\! /Rotate 0 PDF Complaint for Injunctive Relief, Damages, %PDF-1.4 % /Rotate 0 /Type /Page /Resources 137 0 R endobj If the major roll-off collection competitor in a market also controls the primary disposal site(s) therein, other roll-off competitors are at a large disadvantage and entry is difficult. /Rotate 0 /Annots [] /Type /Page 1114 Trademark Infringement . 9 0 obj endobj The HHI increases both as the number of firms in the market decreases and as the disparity in size between those firms increases. However, the incumbents' use of price discrimination and long-term contracts prevents new entrants from winning a large enough base of customers to achieve efficient routes in sufficient time to constrain the post-acquisition firm from significantly raising prices after the transaction. 5. >> /Annots [] The extension of vote-by-mail options and other accommodations at polling places is necessary. /MediaBox [0 0 612 792] This action is brought to /Resources 105 0 R /Type /Page >> /Rotate 0 endstream >> ( /Parent 8 0 R /Rotate 0 "Small container commercial waste collection service" means the business of collecting MSW from commercial and industrial accounts, usually in "dumpsters" (i.e., a small container with one to ten cubic yards of storage capacity), and transporting or "hauling" such waste to a disposal site by use of a front-or rear-end loader truck. /CropBox [0 0 612 792] endobj /Type /Page /Contents [230 0 R 231 0 R 232 0 R] /Rotate 0 /Parent 10 0 R In the Norfolk, VA area, the acquisition would reduce from three to two the number of significant firms competing in the collection of small container commercial waste. /Resources 373 0 R hbbd`b`rfb`gb` # /Resources 257 0 R << /MediaBox [0 0 612 792] /Resources 369 0 R /Type /Page /Type /Page 87 0 obj /Parent 10 0 R This is an action for injunctive and declaratory relief, costs, damages, attorney's fees, penalties, and other available statutory relief, pursuant to the Florida Deceptive and Unfair . 91 0 obj /Resources 181 0 R >> /Annots [] >> /Resources 321 0 R In the Lakeland, FL area, the acquisition would reduce from two to one the number of significant competitors in the collection of small container commercial waste. 64. 28. Suitable landfills are difficult and time-consuming to obtain, and sometimes difficult to expand, because of the scarcity of suitable land, local resident opposition, environmental concerns, and government regulation. << /Rotate 0 2322 0 obj<>stream /Annots [] 14. /Type /Page "Macon, GA area" means the City of Macon and Bibb, Peach and parts of Houston, Jones and Monroe counties, Georgia. endstream >> >> /Contents [138 0 R 139 0 R 140 0 R] endobj stream /Annots [] 77 0 obj /Annots [] /MediaBox [0 0 612 792] 11 0 obj /Rotate 0 /Resources 165 0 R endobj 64 0 obj endobj << 22. /Annots [] This Court has jurisdiction to enter declaratory and injunctive relief pursuant to Florida Statute 86.011 and Article V, 20 of the Florida Constitution. /Title (Microsoft Word - 2022-08-24 - Complaint - FINAL) 88 0 obj<>stream /Type /Page MSW has physical characteristics that readily distinguish it from other liquid or solid waste. Likewise, roll-off customers generate volumes of waste which are too large to be serviced by a FEL truck on a pre-scheduled commercial route. << Obtaining a permit to construct a new disposal facility or to expand an existing one is a costly and time-consuming process, which typically takes many years to conclude. /Rotate 0 /CropBox [0 0 612 792] /MediaBox [0 0 612 792] /Parent 14 0 R /CropBox [0 0 612 792] ( endobj << /Parent 13 0 R /Type /Pages Allied is a Delaware corporation with its principal office in Scottsdale, Arizona. /Kids [15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R 21 0 R 22 0 R 23 0 R 24 0 R] The likely effect of these acquisitions is to substantially lessen competition and to tend to create a monopoly in interstate trade and commerce in violation of Section 7 of the Clayton Act. 22 and 28 U.S.C. /Resources 149 0 R << endobj endobj /Contents [234 0 R 235 0 R 236 0 R] The proposed acquisition would reduce from four to three the number of significant firms that compete in small container commercial waste collection service in the Memphis, TN area. Plaintiff, The Second Amendment Foundation, is a Washington Not-For-Profit /Type /Page /Parent 8 0 R << After the acquisition, Allied would control over 40 percent--and two firms would control over 80 percent--of the small container commercial waste hauling market, which has annual revenues of about $8 million. 1 1 On February 7, 2023 and February 16, 2023, Plaintiff filed motions for preliminary 2 injunctive relief. /MediaBox [0 0 612 792] Allied and Republic directly compete in roll-off waste collection service in a number of markets nationwide, including the Macon, GA area. Roll-off waste compactors are generally located at the site of the roll-off container, thereby permitting the customer to increase the container's on-site storage capacity. It is economically impractical for a roll-off waste collection firm to serve metropolitan areas from a distant base. /CropBox [0 0 612 792] /Rotate 0 ( 31. 66. VERIFIED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Introduction 1. 17. /MediaBox [0 0 612 792] /MediaBox [0 0 612 792] 25 0 obj <> endobj In addition, be sure you have competent, knowledgeable and experienced counsel in your corner. 60 0 obj 4. have exclusive jurisdiction: (a) In all actions at law cognizable by the county . 42 0 obj CASE NO. /Resources 169 0 R /Resources 249 0 R /Rotate 0 >> /Parent 14 0 R 2320 0 obj<> endobj That plaintiff recover the costs of this action. endobj In its 1998 fiscal year, Republic reported total revenues of approximately $1.8 billion. /Type /Page 42. /Resources 161 0 R In this presentation, Jimerson Birr AssociateAustin B. Calhouncovers Florida law on injunctive relief as a remedy, the process for seeking and obtaining injunctive relief through the judicial system, pre-litigation considerations, and enforcement of an injunction order once entered. Security Personnel as Independent Contractors Part I: What Makes an Individual an Independent Contractor Instead of an Employee? /Rotate 0 /CropBox [0 0 612 792] /MediaBox [0 0 612 792] << 59. /Resources 109 0 R /Contents [242 0 R 243 0 R 244 0 R] The Macon, GA area is a section of the country, or relevant geographic market, for purposes of analyzing the effects of the acquisitions under Section 7 of the ClaytonAct. Thus, disposal of MSW is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisition under Section 7 of the Clayton Act. Amended Complaint "Motion") [ECF(the No. COMPLAINT FOR INJUNCTIVE RELIEF AND SANCTIONS Plaintiff, Donald F. Walton, United States Trustee for . and Florida Statute 86.011, et seq. /Parent 11 0 R %PDF-1.3 % /Resources 265 0 R 40. << /Creator (PScript5.dll Version 5.2.2) 35. In re Amendments to Florida Small Claims Rules, 123 So.3d 41 (Fla . /Contents [374 0 R 375 0 R 376 0 R] /Parent 12 0 R /CropBox [0 0 612 792] In each of these markets, the resulting substantial increase in concentration, loss of competition, and absence of reasonable prospect of significant new entry or expansion by market incumbents, ensures that consumers will pay substantially higher prices for collection of small container commercial waste, the collection of roll-off waste, or the disposal of MSW. /Author (JacqmeinV) /CropBox [0 0 612 792] /Resources 245 0 R /Rotate 0 endobj << Does the injunction provide broad or limited relief? H*23430P AsKN$r{(s Complaint for Injunctive Relief Case (s): U.S. v. Allied Waste Industries, Inc. and Republic Services, Inc. endobj Thus, roll-off waste collection service is a line of commerce, or relevant service, for purposes of analyzing the effects of the acquisitions under Section 7 of the Clayton Act. xb```b``Ig`a`X @1V hdc [`&&v/>4427pHG(Og|sW(7_HPpXp'Skgu`.8!B=\2+".b4dh fZ!WHW3`W+.eP9(tb1P,%pX1EaSO6I)1] K,cMpl q m D@,"R:7S&`u@6j(LjfLT[D1,BPf:9= P1!$Ippa8fHNtD {,nPY 5 In such areas, many of the problems associated with the permitting and construction of a landfill could make it difficult to permit and construct a transfer station. 19 0 obj /MediaBox [0 0 612 792] Filing fees $ 402.00 receipt number AFLSDC-16386893, filed by OMEGA SA.. (Attachments: #1 . For a variety of reasons, other types of collection activities, such as roll-off containers (typically used for construction debris) and collection of liquid or hazardous waste, are also rarely combined with commercial waste collection activities. Private waste haulers typically contract directly with customers for the collection of waste generated by commercial accounts.