The Foraker Group

Today we submitted formal comments to the U.S. Census Bureau regarding the proposed changes.  Nonprofit, government, and corporate leaders, we need your voice. You have until November 2, 2026, to submit public comments – but don’t wait! Submit a public comment.

Foraker’s Public Comments:

The Foraker Group (Foraker) opposes all proposed changes to the 2030 Decennial Census. These changes will lead to even more drastic undercounting of Alaskans, which is a significant problem because the State of Alaska has already been labeled as “hard to count” by the U.S. Census Bureau. Removing critical demographic questions and redefining “residence” will profoundly decrease the ability of the census to make a complete and accurate count in 2030 and in turn will greatly diminish the quality of life and access to essential services for all Alaskans. Ultimately, every federal dollar disbursed in Alaska is tied to the census. This amounts to 30% of annual state government spending, which in turn determines how much nonprofits, tribal and local governments, and corporations receive in grants and contracts directly from the federal government and through the State of Alaska and our municipalities.

Specifically, Foraker opposes the following proposed changes:

· The proposed elimination of questions on race, ethnicity, and other demographic information from the census is an unprecedented departure from the longstanding practice of collecting this critical information. Accurate American Indian, Alaska Native, and other race and ethnicity demographic data are essential to understanding the needs and circumstances of the people of Alaska and in particular tribal and other communities that have historically been undercounted. As proposed, eliminating race and ethnicity questions from the decennial census could compromise the accuracy, reliability, geographic specificity, and comparability of American Indian, Alaska Native, and all other peoples’ demographic data produced through related statistical programs, even if those programs continue collecting race and ethnicity information independently.

· The proposed definition of “usual residence” would rely on physical presence during a fixed January 3 through April 1 period, with tax records identified as evidence of residence and an express requirement of lawful presence. This potentially misrepresents where Alaska Native and rural Alaskans ordinarily reside when employment, education, health care, subsistence activities, caregiving, or other circumstances require temporary or seasonal residence away from their home communities. Census data informs federal funding formulas, appropriations, program planning, and civil rights enforcement, including programs serving tribal communities in housing, education, law enforcement, transportation, health, community development, and other essential services. An undercount or miscount can make tribal and rural communities appear smaller or less in need than they are, weakening the data available to support services, resource allocation, and informed decision-making.

· Census demographic data must not be conflated with tribal citizenship or affiliation, nor should tribal enrollment records or other administrative data be presumed to provide equivalent measures of American Indian and Alaska Native populations without demonstrated statistical reliability, meaningful tribal consultation, and respect for tribal data sovereignty. Tribal nations are sovereign political entities, and tribal citizenship is determined by each tribal nation under its own laws. The federal government has a trust responsibility and government-to-government relationship with tribal nations, requiring meaningful and timely consultation on federal actions that may affect tribal governments and their citizens. This is especially important in Alaska, with our 229 federally recognized, sovereign tribes, representing roughly 40% of all such tribal entities in the nation.

Harmful impacts on Americans based on proposed changes

· In the 2020 Census, like virtually every census since statehood, Alaska Native people and all Alaskans were undercounted. The proposed changes make that undercount not only worse but renders these populations virtually invisible.

· The proposed changes, if implemented, would make it more difficult to identify and address discrimination and disparities. Demographic census data is necessary to enforce civil rights laws, such as the Voting Rights Act and the Fair Housing Act, and to ensure equal opportunity for all Americans. Without this information, it will be harder for communities to identify and redress longstanding racial, social, and other disparities or to serve underserved communities.

· The decennial census establishes population benchmarks that support other essential U.S. Census Bureau statistical products, including the Population Estimates Program, which produces annual population estimates, and the American Community Survey, which uses population estimates to weight survey responses and produce demographic, economic, and housing statistics. The proposed changes will impact all these other statistical products, rendering them less reliable and less accurate.

· Eliminating demographic data undermines the ability of nonprofits, businesses, researchers, and policymakers to make informed decisions and to guide economic development and business planning. Nonprofits and businesses use census data to make critical decisions about where and how to invest resources and any changes inhibits their ability to appropriately serve Alaskans.

· Policymakers use census data to better understand changing communities and their unique needs.

· Researchers use census data to minimize statistical bias and to evaluate the effectiveness of programs and policy.

· The proposed regulation would deprive local communities of vital resources used by all Alaskans, shifting resources away from the people and places federal programs are intended to serve.

· The proposal also undermines public trust in the census itself, along with trust in how census data is used. Incomplete or contested outcomes threaten public confidence in our democracy. Every community deserves its fair share of resources and political power, and proposals that undermine public trust put our democracy at risk.

· The proposed changes to the 2030 Decennial Census would alter the definition of “usual residence” and prohibit the collection of race and ethnicity information through the decennial enumeration, eliminating an established source of directly reported American Indian and Alaska Native population data and potentially undermining the reliability and comparability of related demographic statistics.

Requests for action

· Foraker requests that the U.S. Census Bureau and U.S. Department of Commerce withdraw the proposed regulations and preserve the direct collection of race and ethnicity information through the decennial census and established residence-enumeration practices.

· Foraker requests that the U.S. Census Bureau conduct and share a comprehensive impact analysis identifying federal programs, funding formulas, appropriations, statistical products, and civil rights enforcement activities that rely on race and ethnicity questions in the census demographic data, including the potential impacts on Alaska tribes and Alaska Native communities.

· Foraker requests that the U.S. Census Bureau assess and publicly disclose how the proposed changes would affect the Population Estimates Program, the American Community Survey, and other statistical products that depend on decennial census data, including their ability to produce accurate, reliable, comparable, and geographically specific American Indian and Alaska Native population and household estimates.

· Based on the hard-to-count nature of Alaska, Foraker requests that the U.S. Census Bureau work with tribal nations to improve the accuracy and completeness of American Indian and Alaska Native enumeration, preserve the visibility of multiracial American Indian and Alaska Native people, and protect the demographic data needed to understand and address disparities.

· As an ally to sovereign tribal nations, Foraker requests that the federal government uphold its trust responsibility and government-to-government obligations by ensuring that changes to census methods do not proceed without meaningful and direct tribal engagement, not merely administrative rulemaking but true tribal consultation and transparent assessment of foreseeable impacts on tribal self-governance and essential services.

· Foraker requests that any proposed “usual residence” criteria undergo tribal-specific testing and overall analysis that accounts for Alaska Native people and all people living in Alaska who spend time away from their communities for work, education, health care, caregiving, military service, incarceration, housing instability, or other circumstances.

· Alaska is preparing for a dramatic influx of military personnel deployed to our state. This influx will greatly strain housing and human resource services in Alaska. Complete and accurate census data must account for this influx and its impacts.

The bottom line is that the decennial census must provide a complete and accurate count of every person living in Alaska and as such meet the requirements established in the U.S. Constitution 250 years ago.

Respectfully submitted, The Foraker Group