Kindred Futures has submitted a public comment opposing the Census Bureau’s proposed changes to the 2030 Census. The proposed rule, published in the Federal Register on September 10, 2026, would change who is counted, where they are counted, and whether they are counted by race. The full comment is embedded at the end of this post.
The Bureau proposes three changes. First, it would replace the 2020 residence standard, which counts each person where they live and sleep most of the time, with a test tied to tax records and a thirteen-week enumeration period. Second, it would exclude residents from the apportionment count on the basis of immigration status. Third, it would remove the race and ethnicity questions from the 2030 questionnaire.
Our policy and research work depends on decennial census data to measure wealth, displacement, and economic conditions across the South. The South is home to 56 percent of the nation’s Black population, and the 2020 Census already recorded a net undercount of the Black population of 3.30 percent nationally, with the largest state-level undercounts concentrated in Southern states. Census-derived data guided $2.8 trillion in federal spending across 353 programs in fiscal year 2021. A rule that deepens the undercount and removes the data needed to measure it would affect representation and funding in the communities we serve for decades to come.
What we asked the Bureau to do
Our comment makes four recommendations:
- Withdraw proposed § 60.2 and retain the 2020 standard that counts each person where they live and sleep most of the time as of Census Day, without a tax-records test or a one-hour-per-day threshold.
- Withdraw proposed § 60.4 and count every person residing in each state regardless of immigration status, consistent with Section 2 of the Fourteenth Amendment.
- Withdraw proposed § 70.2(a) and retain the race and ethnicity questions on the 2030 Census questionnaire.
- Publish a regulatory impact analysis, before issuing any final rule, that estimates the undercount, apportionment, and federal funding effects of each provision by state and by race and ethnicity, as Executive Order 12866 and OMB Circular A-4 require.
The comment also addresses the Bureau’s stated rationale. The Bureau describes the proposal as a return to the 1790 Census, but the First Census Act defined residence by a person’s usual place of abode, not by tax records or a thirteen-week window, and Section 2 of the Fourteenth Amendment directs the Bureau to count the whole number of persons in each state. The Bureau offers no estimate of how removing the race question would affect response rates, and the notice certifies that the rule is not economically significant even though it would reallocate congressional seats and $2.8 trillion in annual federal spending among the states.
How to submit your own comment
Comments are due by Nov 2, 2026. The Bureau extended the original October 13 deadline in an October 5 notice. Every comment becomes part of the public record the Bureau must consider before issuing a final rule.
- Submit online through the Regulations.gov comment form for docket USBC-2026-0628. The docket page lists all comments received.
- Read the proposed rule in the Federal Register (91 Fed. Reg. 57524).
On October 9th, 2027, Kindred Futures hosted a rapid response call walking through the proposed rule and our comments, as well as steps advocates can take to submit their own rules in partnership with Hands Off Census.
You can view the recording here.
Comments do not need to be long or technical. The most useful comments state who you are, which part of the rule you are addressing, and what the change would mean for your community or organization. Our comment is available below as a reference.
Kindred Futures’ comment to the Census Bureau
