On October 29, we submitted a comment to the Department of Commerce on the proposed rule entitled “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions.” This rule seeks to redefine “usual residence” to exclude most non-citizens from the apportionment count, and eliminate direct, self-reported race and ethnicity questions.

We urge the Department of Commerece to uphold the Constitutional requirement to count “the whole number of persons in each State” in Decennial Census, and nearly 250 years of settled administrative administrative practice, and withdrawal this Proposed Rule in its entirety.

The Proposed Rule threatens to directly harm American democracy and the communities that depend on an accurate Census count. A Census that undercounts millions of residents weakens the representational link between people and their government, shifts political power away from the communities least able to absorb that loss, and cuts off the flow of federal funding that the schools, hospitals and clinics, emergency services, and countless other types of public infrastructure rely on for a decade or even longer. Those harms will not be evenly distributed: they will fall hardest on immigrant families, women and caregivers, communities of color, and people living in poverty who are already the most difficult to count. Read the entire comment linked here.