The decennial census plays a critical role in shaping political representation, guiding public policy and informing the distribution of federal resources to communities across the United States. The U.S. Census Bureau recently proposed changes for the 2030 Census.

In response, the Kresge Foundation submitted a public comment letter expressing the foundation’s concern that several of the proposed revisions could undermine the accuracy, completeness and usefulness of the nation’s population count. Specifically, Kresge voiced its opposition to proposals that would exclude certain noncitizen residents from the apportionment count, redefine long-standing residence standards in ways that could increase undercounts among vulnerable populations and eliminate key demographic questions related to race, ethnicity and sexual orientation. Here is the full letter: 

On behalf of The Kresge Foundation, I am writing to express our foundation’s strong opposition to the U.S. Census Bureau’s proposed rules governing residence criteria and demographic questions for the 2030 U.S. Census.

It is our view that these rules would:

• Exclude potentially millions of noncitizen residents, who lawfully reside in the United States but do not hold lawful permanent resident status, from the apportionment count;
• Redefine usual residence in a way that will systematically miscount or overlook millions of Americans; and,
• Unnecessarily prohibit the collection of demographics of Americans that would have a deleterious impact on the allocation of federal, state and municipal funds and charitable donations.

With this letter, we wish to publicly state our opposition and to outline the various ways we believe these planned changes to the U.S. Census would harm the communities that our foundation serves.

The Kresge Foundation is one of the nation’s oldest and largest philanthropic foundations and a leader in expanding equity and opportunity in America’s cities. We invest more than $160 million annually through grantmaking and social investments across the arts and culture, higher education, environment, health and human services sectors. Kresge is also the preeminent national foundation devoted to place-based community development in the United States, principally in the cities of Detroit, Memphis, New Orleans and Fresno.

Kresge submits these comments because accurate, reliable and sufficiently detailed census data are essential to carrying out our charitable mission. Our experience supporting place-based community development, health, education, human services and other charitable initiatives gives us a direct and practical perspective on how changes to census methodology affect communities, nonprofit organizations and philanthropic decision-making.

The U.S. Constitution requires an “actual Enumeration” of the “whole number of persons in each State.” The first Census Act directed enumerators to count every person at their “usual place of abode.” And since 1790, the U.S. Census Bureau has honored that constitutional obligation without regard to citizenship or an individual’s legal status. The U.S. Census Bureau’s proposed residence criteria abandon this long-held ethic.

Under the proposed rule, individuals who are not U.S. citizens or lawful permanent residents (i.e. green card holders) would be excluded from being counted.

This new rule would, therefore, impact everyone whose status the U.S. Census Bureau sees as “less durable and indefinite in length than lawful permanent residency,” including international students, H-1B highly skilled workers and other temporary visa holders, DACA recipients, pending asylum applicants, refugees and people with Temporary Protected Status. This is a significant departure from all previous census counts dating as far back as the founding of the Republic.

Under the proposed rule, individuals who are neither U.S. citizens nor lawful permanent residents would be generally excluded from the apportionment count, detrimentally impacting Congressional reapportionments and potentially diverting federal funds from communities and states that may need these resources the most.

Second, we are equally concerned about the criteria the new proposal would use to calculate “usual residence,” which would lean heavily on tax records and an arbitrary time period of January 3 to April 1. Reliance on those criteria risks producing a less accurate and less representative count and fails to enumerate, for instance, families who move during the year, people experiencing housing instability, migrant workers, foster youth, college students and young children – who were already the most undercounted age group in 2020, with an estimated national undercount of one million children.

In Michigan, for example, the consequences of this approach could extend well beyond the populations the rule appears to target. The January-to-April enumeration window coincides precisely with “snowbird” season, when many Michigan residents spend part of the winter in warmer states. Some communities in northern Michigan lose a substantial share of their population during this period. A residence standard built on where someone spends the winter could result in some Michigan residents being assigned outside the state or otherwise inaccurately counted, with consequences for Michigan’s congressional representation and for the state legislative maps drawn from the same data.

The U.S. Census Bureau also plans to prohibit questions about race, ethnicity and sexual orientation on the primary census form. The proposed restriction would represent a significant departure from the longstanding use of a decennial census to collect demographic information, including information about race and ethnicity.

This element of the proposal would do lasting damage to the nation’s capacity to count and understand the growth or decline of America’s population. The census has asked about race since 1790, and those responses have become the evidentiary foundation for nearly every civil rights protection the country has built.

We note as well that the U.S. Census Bureau arrived at updated race and ethnicity standards in 2024 following years of research, testing and public engagement, including the addition of a Middle Eastern or North African (MENA) category that communities had sought for three decades. Implementation has been delayed, and this new category did not appear in the U.S. Census Bureau’s 2030 test sites. This proposal would complete that reversal, discarding the standards and the long effort by MENA communities to secure recognition in the count.

Although not part of this proposed rule, these changes should also be considered alongside the U.S. Department of Commerce’s separate decision regarding the discontinued use of differential privacy, the method the U.S. Census Bureau uses to protect individual confidentiality in small-population areas while still producing valid estimates. The method was rigorously tested before its use in the 2020 U.S. Census. Without it, the U.S. Census Bureau will fall back on older techniques that either round data into broad categories or withhold them entirely. Together, these changes could further reduce the availability and reliability of granular population data used by governments, nonprofit organizations and philanthropy.

Kresge’s hometown of Detroit offers a clear illustration of what an undercount can cost a city and how methodology can erase residents. After the 2020 census, the city of Detroit filed a federal lawsuit challenging what it described as a racially biased undercount in the U.S. Census Bureau’s annual population estimates. The complaint argued that the U.S. Census Bureau’s methods fundamentally disadvantaged older urban cities by relying heavily on housing unit counts, subtracting residents for every demolition while crediting only new construction. In effect, a city that demolished blighted structures and rehabilitated existing ones loses population on paper while gaining it in fact. Detroit calculated that its housing units were undercounted by the U.S. Census Bureau by more than 11,000 across a two-year period. Experts who studied the city’s count agreed it was undercounted, at a cost of millions of dollars annually in federal funds.

That is the harm under the administration’s current methodology. The proposals now before the U.S. Census Bureau would compound it. Detroit is precisely the kind of place where a tax-record residence standard and the elimination of race and ethnicity data would do the most damage. Detroit cannot absorb another decade of being undercounted.

How the U.S. Census Bureau conducts its count and population analysis deeply impacts how philanthropy decides to make its own charitable investments. Much of our grants and social investments are grounded in census data – as are the decisions of the community development financial institutions we capitalize, the health and higher educational systems we partner with and the municipalities and nonprofit organizations that carry out work in community. When the count is wrong, capital flows away from the communities that potentially need it most.

We, therefore, respectfully urge the U.S. Census Bureau not to adopt the proposed residence criteria and instead to retain a usual-residence standard that counts individuals based on where they ordinarily live. We also urge the U.S. Census Bureau not to adopt the proposed restriction on race, ethnicity and sexual orientation questions and to implement the 2024 federal race and ethnicity standards following appropriate testing and public engagement.

The census is the country’s accounting of itself, and its integrity has rested for more than two centuries on a simple proposition: if you live in the United States of America, you count. I hope you will reconsider these proposals and uphold that standard.

Thank you for your consideration.

Sincerely,
Rip Rapson
CEO & President
The Kresge Foundation