On October 28, six former U.S. Census Bureau directors, who served between 1994-2025, submitted comments expressing opposition to the proposed decennial census rule, “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions.”
In their comments, the directors wrote “As former directors of the U.S. Census Bureau, serving under administrations of both parties, we are concerned that this approach is likely to make the count less accurate, not more. The proposal will complicate what the Constitution calls for: an “actual Enumeration.” That obligation should be carried out with residence rules that reflect a readily understood concept of where and how people actually live, which has been thoroughly researched and tested, and can be administered consistently across the country.”
The former directors state that the rule does not reflect the essential rigorous testing and evaluation that is required before pursuing changes to the decennial census questionnaire and the conduct of the count.
“Before changing foundational residence rules, the Department of Commerce should conduct end-to-end and operational testing; measure effects on coverage, duplication, and geographic allocation; publish the findings, and allow independent experts, stakeholders, and the public to evaluate the results. The Department should also explain how it would resolve conflicts, protect confidential tax information, and preserve clear, workable rules for complex living arrangements, including families sharing a home, auxiliary dwelling units, and renting of a portion of a home.”
The directors state the “…proposed changes in content that depart from every U.S. Census conducted since 1790, leads us to strongly oppose all changes described in the Federal Register.”
The public comment period closes November 2.
