On November 2, 2026, GBPI submitted the following comment on proposed changes to the census that would result in the loss of information critical to economic and policy planning and evaluation. You can submit your own comment here.
Re: Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions (Federal Register Number: 2026-18481, Federal Register Citation: 91 FR 57524, Document ID: USBC-2026-0628-0001)
To Proposed Rule Comment Reviewers c/o Daniel Sweeney, Deputy General Counsel for Economic, Statistical, and Regulatory Affairs, Office of the General Counsel, Department of Commerce:
Georgia Budget and Policy Institute (GBPI) appreciates the opportunity to comment on the proposed rule, “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions.”
GBPI is a non-profit, non-partisan research and advocacy organization focused on analyzing Georgia’s state budget and advancing policy solutions that expand economic opportunity and well-being for all Georgians. Decennial census data provides foundational information for state fiscal planning and budgeting, including federal formula grant funding allocations to the state, and policy prioritization, planning, monitoring and evaluation. Given this, GBPI opposes proposed changes to the decennial census that would compromise the accuracy, completeness, and comparability of the 2030 Census and encourages the Census Bureau to preserve the integrity of the decennial census.
An accurate count of Georgia’s population is essential for budget and policy planning
States rely on census counts that accurately reflect the population of people that live in them. This information is integral to every facet of state-level budget and policy planning, including federal funding contributions. The decennial census supplies the data used in benchmark counts, survey weights and geographic-area denominators, which are critical to economic forecasting, calculating population-level rates (e.g., unemployment, crime, disease prevalence, etc.), and determining a state’s fair share of federal assistance programs and other grants.
The proposed changes to residence criteria in the decennial census will generate a population count far lower than the actual number of people living in Georgia. This would undermine Georgia’s ability both to generate accurate fiscal projections and to evaluate existing policies. It also would set Georgia up for severe budget shortfalls by underestimating Georgia’s population in the census data used in core grant formulas for federal funding. This would result in insufficient funds for programs that serve Georgians, especially those experiencing economic insecurity.
Given that the proposed change to residence criteria would result in inaccurate and incomplete population estimates that would destabilize Georgia’s budget and undermine the state’s ability to enact effective and evidence-based policies, GBPI urges the Census Bureau to withdraw this proposed change and continue counting all persons residing in the United States.
Complete and comparable data is critical to economic and policy evaluation
Economic and legislative policies are implemented at a population level. Yet research has repeatedly shown that population-level policies can have heterogeneous effects among different groups within the overall population. This is due to multiple factors, including the cumulative effect of past policies that create a different baseline for different populations. In Georgia and other states, for example, past policies related to zoning, mortgage insurance and deed covenants created geographic disparities in home ownership by race and ethnicity. Given that home ownership is the primary mechanism for middle-class asset and wealth building over time, these past policies created different population-level baselines in property ownership and net worth by race and ethnicity that persist today.
In order to accurately evaluate whether a policy results in the intended effect among all Georgians (or has unintended negative consequences among some Georgians) and identify strategies to improve overall policy effectiveness and efficiency, Georgia must have access to sociodemographic population characteristics, including race and ethnicity. Prohibiting the inclusion of questions about race and ethnicity or sexual orientation on the decennial census short-form questionnaire or any questionnaire used for purposes of the enumeration would deprive Georgia (and other states) of complete information about its resident population. As such, it would impede Georgia’s ability to compare outcomes, examine changes over time, measure progress, and determine policy priorities that expand economic opportunity and well-being for all Georgians.
Given that the proposed change to demographic questions would result in the loss of information critical to economic and policy planning and evaluation, GBPI urges the Census Bureau to withdraw this proposed change to restrict the inclusion of demographic questions about race, ethnicity and sexual orientation.
Conclusion
States rely on the federal government to conduct the decennial census and provide accurate population data. This data is critical to state budget and policy planning, economic forecasting and evaluation. GBPI urges the Census Bureau to preserve the integrity of the decennial census and ensure the accuracy, completeness and comparability of the 2030 Census.
Sincerely,
Sonia Tetlow, PhD
Director of Economic Security
Georgia Budget and Policy Institute
