March 5, 2026
Sheleen Dumas
Departmental PRA Clearance Officer
Office of the Under Secretary for Economic Affairs
U.S. Department of Commerce
Washington, DC 20253
Re: 2026 Operational Test in Support of the 2030 Census (FR Doc. USBC-2026-0034)
Dear Ms. Dumas:
The undersigned organizations and individuals are writing to express their strong opposition to
several components of the 2026 Operational Test in Support of the 2030 Census described in
the Federal Register Notice Docket Number USBC-2026-0034, “Agency Information Collection
Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval;
Comment Request; 2026 Operational Test in Support of the 2030 Census” (the “February
Notice”).
We are a group of national and community-based organizations, advocates, Latino elected and
appointed officials, and other Latino civic leaders, and many of us worked closely with the
Latino community to promote participation in Census 2020 as well as prior decennials.
For the reasons set forth below, the proposed 2026 Census Test described in the February
Notice would prevent the Bureau from conducting the assessment of enumeration strategies
among a representative population of Latinos that is needed to reach and engage
geographically, linguistically, and residentially diverse hard-to-count Latino communities. The
plan lacks scientific rigor and would produce fundamentally flawed and incomplete data,
impairing effective planning and worsening the persistent undercount of Latinos. It would also
limit the Bureau’s ability to improve cost-effectiveness and efficiency in Census 2030.
I. Introduction
Accurate and complete decennial census data help make our democracy stronger and are essential to
safeguard the nation’s prosperity and well-being. According to 2024 American Community Survey
(ACS) data (one-year estimates), one in five U.S. residents is Latino (20.0%), and an accurate national
count is impossible without a full and accurate count of the Latino community. For the Census Bureau
to make sound and cost-efficient preparations for Census 2030, it must undertake thorough and
scientifically rigorous evaluation of its outreach and operational methods which will produce reliable
and useful results to inform its efforts for an accurate decennial enumeration of the Latino community.
There is a particularly critical need for sound evaluation of the Bureau’s outreach and
operational methods given the severe and historic national net undercount of Latinos in Census
2020 (4.99%). Moreover, there has been a persistent national undercount of very young Latino
children (ages 0-4), which researchers William O’Hare and Susana Quiros found reached
8.6% in Census 2020, nearly double the national undercount of all very young children (5.4%).
The Census Bureau cannot develop effective strategies to ameliorate these undercounts without
thorough research and assessment which encompass approaches to reaching the full diversity
of hard-to-count Latino population groups.
In 2024, the Bureau announced a comprehensive plan for a 2026 Census Test of Census 2030
field operations. It had selected six test sites to evaluate enumeration strategies, using data and
other criteria to select sites with an overall emphasis on designing strategies to improve
enumeration of historically undercounted or hard-to-count populations. As part of its criteria,
the Bureau explicitly indicated that it intended to select some rural sites, and areas with low or
no Internet or cellphone connectivity.
The Bureau also intended to assess other operational components such as the Group Quarters
operations; the full range of self-response modes (mail, telephone, and Internet); and
partnership and field strategies, including Mobile Questionnaire Assistance (MQA). The test
would have used the decennial Census questionnaire, with translation of materials into Spanish.
Finally, the Bureau’s initial proposal included a mailing to a national sample of the population.
As part of its planning, the Bureau engaged its 2030 Census Advisory Committee (CAC) and
other advisory committees in its efforts, through presentations and discussions. This process
provided significant transparency for the Bureau’s planning, and an opportunity for consultation
with and input from stakeholders with expertise on diverse population groups. Arturo Vargas of
the NALEO Educational Fund chaired the 2030 Census Advisory Committee, and it provided
recommendations to the Bureau on certain aspects of the 2026 Census Test, as part of its
mission to enhance accountability from the Bureau.
In January 2025, the Bureau released a Federal Register Notice soliciting comments which
suggested it intended to proceed with the 2026 Census Test as initially planned. However, after
the release of that Notice, the Bureau failed to provide the public with any updates about the
2026 Test, until the February Notice. During that period, the Department of Commerce also
abolished the 2030 CAC and other Bureau advisory committees, claiming they had fulfilled their
purposes. The elimination of the advisory committees further contributed to the failure of the
Bureau to obtain input on the 2026 Census Test from experts and other stakeholders, and the
lack of transparency about the Bureau’s future plans for the test.
II. The Bureau’s proposed changes to the 2026 Census Test will produce
fundamentally flawed results, setting Census 2030 up for failure by undermining
the Bureau’s ability to accurately count Latinos and the entire nation
There are several components of the Bureau’s proposed changes to the 2026 Census Test that
would severely impair the sound and scientifically rigorous assessment needed for the Bureau’s
Census 2030 preparations. In particular, the following deficiencies will prevent a fair and
accurate decennial count of Latinos:
1. Reduction of test sites
The Bureau plans to eliminate four of the test sites it initially proposed, leaving only
Spartanburg, South Carolina and Huntsville, Alabama, neither of which have significant Latino
populations. By eliminating the site in Western Texas, which includes colonias, the Bureau will
fail to assess operations in a rural area with a large Latino population which has been
historically undercounted for several reasons. This area includes Latino residents who lack
Internet or cellphone access, and may have low English-language proficiency and data literacy.
Many Latinos in this region also live in “hidden housing” (such as converted garages, sheds, or
trailers) or in residences with non-mailable addresses.
Eliminating the site in Colorado Springs further excludes suburban Latinos and those living in
military installations. The proposed 2026 Census Test site reductions would also neglect tribal
communities in Arizona and Western North Carolina. Ultimately, scaling back test sites would
prevent assessment in areas that more fully reflect the nation’s population and would severely
limit the Bureau’s ability to evaluate strategies for reaching geographically, linguistically, and
residentially diverse Latino communities. In this connection, in its report on its fiscal year 2026
Commerce, Science, and Justice appropriations bill, the Senate Appropriations Committee
underscored the importance of carrying out the 2026 Census Test in “geographically and
demographically diverse field sites nationwide, and with a nationally representative sample of
households,” and called on the Census Bureau to “ensure the objectives of the 2026 Census
Test are fully realized.”1
2. Use of questionnaire which includes a citizenship question
We understand the Bureau intends to use a version of the ACS questionnaire in the 2026
Census Test, a form which is much lengthier than the decennial form and includes a citizenship
question. First, using a questionnaire that is significantly different from the one that will be used
in the 2030 Census undermines testing of true decennial census operations. It is not
scientifically valid and would not produce useful information to improve 2030 Census operations
and outreach.
Additionally, extensive research shows that a citizenship question deters participation among
Latino and immigrant communities. In 2019, the Supreme Court blocked the addition of a
citizenship question to the 2020 Census because the first Trump administration attempted to do
so illegally. The current administration has indicated it will again attempt to add such a question
for Census 2030. Testing this question only in sites without significant Latino or immigrant
populations would likely mask its harmful effects and generate misleading data — potentially
paving the way for its inclusion in 2030.
3. Elimination of mail and phone response testing
The Bureau would test only Internet response. However, while the digital divide has narrowed,
many Latino households still lack broadband access or digital literacy, and many have preferred
to respond to the Census by mail or phone. For example, a 2021 Pew Research Study showed
that Latinos had less access to home computers than non-Hispanic Whites (67% compared to
80%), as well as lower access to home broadband (65% compared to 80%).
1 U.S. Senate Committee on Appropriations. (2025). Departments of Commerce and Justice, Science, and
Related Agencies Appropriations Bill, 2026 (Senate Report No. 119-44). U.S. Government Publishing
Office.
Limiting the 2026 Census Test to Internet-only responses—and excluding sites with large Latino
populations that lack broadband access (as noted above)—will not produce reliable data on how
to reach the hardest-to-count communities. Failing to test mail and phone response modes
ignores longstanding Latino response patterns, limiting the Bureau’s ability to make sound
assessments to improve participation.
4. Removal of the national sample component
The current proposal does not include any national self-response testing component, which
harms the representativeness of the 2026 Census Test’s sample. This failure will significantly
weaken the Bureau’s ability to develop effective Census 2030 messaging, mailing strategies,
and materials that would improve self-response rates.
5. Elimination of Spanish-language Internet testing
The Bureau has also indicated that it will not translate response materials into Spanish.
However, according to 2024 ACS data (one-year estimates), 29% of Latinos lack full fluency in
English, and the lack of Spanish-language materials would prevent meaningful testing of
strategies to engage these Latinos, who are already at high risk of undercount.
6. Removal of community engagement and assistance components
The Bureau’s proposed plan would eliminate assessment of community partnerships and trusted
messengers; communications strategies; and MQA operations. Community engagement and
assistance strategies have proven critical in reaching hard-to-count Latino communities and
building trust, which is even more important in an environment where the Administration’s
aggressive immigration enforcement activities and data-sharing practices have created
widespread fear in Latino and immigrant communities about having any contact with or
providing personal information to federal government employees.
Failure to assess community partnership strategies in the 2026 Census Test is particularly
egregious given the Commerce Department’s abrupt termination of the Census Bureau’s
advisory committees in February 2025. As noted above, the advisory committees served as a
critical forum for gathering input from stakeholders with expertise in reaching undercounted
communities, and failure to test approaches to engaging community partners will exacerbate
this loss.
7. Elimination of Group Quarters component
This proposal does not include any testing of Group Quarters enumeration, even though
Spartanburg and Huntsville were originally selected as test sites due in part to the variety of
group quarters facilities they include. Many Latinos reside in group quarters; failing to test these
operations neglects a significant segment of the community.
8. Proposed testing of USPS workers for in-field enumeration
The proposal to test the use of United States Postal Service (USPS) employees for in-field
enumeration presents serious operational, legal, and cost-efficiency concerns. Prior research2
has indicated that such an approach could increase costs and delay mail service3. More
fundamentally, unresolved conflicts between Title 13 confidentiality protections governing
Census Bureau employees and Title 39 provisions applicable to USPS employees create
unacceptable risks regarding data confidentiality. Until these legal discrepancies are resolved
transparently and definitively, such testing should not proceed.
Ultimately, the Bureau’s proposed 2026 Census Test revisions would irreparably damage the
foundation needed to ensure an accurate count of Latinos in Census 2030. Without sound and
meaningful testing, the nation risks deepening disparities that prevent fair resource allocation
and representation for Latino communities.
III. Recommendations and Conclusion
The proposed 2026 Census Test would produce results that lack scientific rigor and would
prevent effective preparation for a fair and accurate Census 2030. Proceeding with the test as
described in the February Notice would also constitute a gross misuse of the funds Congress
has appropriated to the Bureau to improve the efficacy, accuracy, and cost-efficiency of census
operations and outreach. Ultimately, the proposal would set Census 2030 up for failure,
jeopardizing the quality of Census data for at least the next decade.
We therefore urge the Department of Commerce to:
Restore all six originally planned field test sites.
Use only the decennial census form for the 2026 test, without the inclusion of a citizenship
question.
- Restore comprehensive testing of mail, phone, and multilingual Internet response modes.
- Reinstate the national sample mailing and self-response component.
- Restore testing of community outreach, partnerships, and mobile assistance strategies.
- Restore testing of Group Quarters enumeration.
- Eliminate proposed testing of USPS employees for enumeration unless legal and operational
- concerns are fully resolved.
- Ensure transparency by publishing a detailed analysis of test results and engaging
- meaningfully with stakeholders.
Thank you for considering these comments. We appreciate the opportunity to provide input on
this critical matter and stand ready to work with the Department of Commerce and the Census
Bureau to ensure that the 2026 Census Test and the 2030 Census are conducted with integrity,
scientific rigor, and a commitment to accurately counting Latinos and every community.
Please contact Rosalind Gold, Chief Public Policy Officer of the NALEO Educational Fund,
[email protected], if you have any questions about this letter.
Sincerely,
Organizations
afrolatin@ forum
Afro-Latino Coalition
Alianza Center, Inc
Arab American Institute (AAI)
Catholic Charities New York
Chinese-American Planning Council (CPC)
Coalition on Human Needs
Common Cause
Community Resource Center
Hispanic Federation
Immigration Resource Center of San Gabriel Valley
Labor Council for Latin American Advancement (LCLAA)
LADEI
Latino Community Foundation
LatinoJustice PRLDEF
League of United Latin American Citizens (LULAC)
MACS 2030 - Minnesotans for the ACS and 2030 Census
Make the Road New York
Make the Road States
Massachusetts Immigrant and Refugee Advocacy Coalition
Mi Familia en Acción
Mi Familia Vota
National Association of Hispanic County Officials (NAHCO)
National Dominican Women's Caucus
National Haitian American Elected Officials Network (NHAEON)
National Hispanic Media Coalition
National Network for Arab American Communities
New Jersey Institute for Social Justice
New York Women’s Chamber of Commerce
Prison Policy Initiative
Progreso Latino
The League of Women Voters of the United States
YMCA of Greater New York
Local Governments
City of Bell Gardens, California
Westchester County, New York
Individuals (Affiliations provided for identification purposes only)
Julio Batista
Danilo Burgos, Pennsylvania State RepresentativeMs. Sheleen Dumas
March 5, 2026
Page 7
Elizabeth De La Riva
New York City Council Member Carmen De La Rosa
Lesly Devereaux
Commissioner Adrian Garcia, Harris County Precinct 2
Professor Tanya K. Hernandez
Daniel Meza
Cheryl Naluai
Christine Primomo
Ross Romero, Salt Lake County Councilman
Gumaro Armando Silva
Jo Anne Simon, New York State Assemblymember
Lila Valencia, Ph.D.
Eli Valentin
2 U.S. Census Bureau. (2019). 2020 research and testing: Proposed postal carriers as Census Bureau
enumerators pilot (Final Analysis Report). https://www2.census.gov/programs-
surveys/decennial/2020/program-management/final-analysis-reports/2020-report-postal-carriers-census-
enumerators-pilot.pdf
3 Government Accountability Office. (2011). Decennial Census: Census Bureau and Postal Service should
pursue opportunities … (GAO-11-874). https://www.gao.gov/assets/a585539.html