NLIHC, DHRC Submit Comment Letters Opposing Harmful Changes to Census; Nearly 150,000 Comments Submitted, With Vast Majority Opposed to Census Proposal

By Renee Williams, NLIHC Senior Advisor for Public Policy and Tia Turner, NLIHC Project Manager, Our Homes, Our Votes 

On November 2, both NLIHC and the Disaster Housing Recovery Coalition (DHRC) submitted letters opposing drastic proposed changes to the decennial Census. For a summary of the proposed changes, see Memo, 10/5.  

These changes would lead to an inaccurate Census count and have numerous negative downstream consequences for the distribution of federal funds (including housing and community development dollars), data accuracy, disaster preparedness and recovery, and fair housing enforcement, among other effects. 

Partners such as the Hands Off Our Census Campaign, the Roadmap to the 2030 Census initiative, and Puerto Rico Cuenta called attention to the harmful changes proposed by the Census Bureau and mobilized comments in opposition.  

Leader Stacey Abrams recently discussed the importance of an accurate Census in her Substack “Assembly Notes by Stacey Abrams,” using her platform to highlight NLIHC’s analysis connecting the Census and equitable access to housing families can afford.  

Nearly 150,000 comments were submitted during the public comment period. As of November 2, 89 percent of the comments analyzed by Hands Off Our Census opposed the proposed changes.  

The Census Bureau, which is part of the Department of Commerce, now must review the submitted comments, respond to substantive comments, and make any changes before the proposal can be finalized. 

NLIHC Comment Letter 

NLIHC’s comments, joined by numerous organizations that signed on, made the following points: 

• The Census proposal to exclude from the apportionment count individuals who are not U.S. citizens or legal permanent residents is inconsistent with the Constitution’s plain text. 
• The Census proposal, if implemented, would result in undercounts within many communities, disadvantaging their states in the apportionment process and denying those states fair representation in Congress. Crucial decisions about funding federal housing programs are made by Congress. Congress also plays a role in essential oversight of departments that administer federal housing programs serving millions of Americans, such as HUD. 
• An inaccurate population count in the 2030 Census would also create uncertainty across important housing and community development programs that states and communities rely upon, such as the Community Development Block Grant program. 
• The proposed changes would create distrust in the Census, lower response rates, and result in lower-quality data needed for housing research.  
• The proposed bar on race, ethnicity, and sexual orientation questions for the decennial Census would negatively impact civil rights enforcement and lead to lower-quality federal data. 
• The comment period was too short given the significance of the proposed changes. 

NLIHC urged the Census Bureau to withdraw its proposed changes to the Census in their entirety. 

DHRC Comment Letter 

The DHRC comments made the following points: 

• The proposed changes fail to account for the prevalence of long-term displacement of disaster-impacted households and will lead to incorrectly counting these households elsewhere or excluding them from Census counts altogether. 
• Federal programs at multiple agencies, state and local governments, and first responders rely on accurate Census data for disaster and emergency operations and planning. An inaccurate count would harm the effectiveness of these programs in saving lives and property. 
• The proposed changes would have particularly negative effects on the U.S. territories, which have disproportionately suffered the impacts of extreme weather and resulting disasters, heightening the stakes for accurate data collection. 
• The proposed changes would negatively impact efforts to respond to disasters and emergencies equitably across communities. The race and ethnicity data collection that the Census Bureau seeks to prohibit for the decennial Census is needed to ensure that disaster responses do not retrench historic patterns of racial segregation. 
• Creating distrust surrounding the Census will sow additional chaos and confusion for disaster survivors and further chill engagement with all government entities, including lifesaving services provided during disaster responses. 

The DHRC comments also called for the withdrawal of the Census proposal.  

Read NLIHC’s comments. 

Read the DHRC comments. 

Read the “Assembly Notes by Stacey Abrams” piece connecting the Census and housing. 

Read the Census Proposed Rule.