Six former Census directors say the 2030 census plan would make the count less accurate

Six former directors of the U.S. Census Bureau, who led the agency under presidents of both parties between 1994 and 2025, have urged the Commerce Department to drop its proposed rules for the 2030 census. In a comment filed October 28, they wrote that the plan "is likely to make the count less accurate, not more."

The signers are Ron Jarmin, acting director in 2025, 2021-22, and 2017-19; Robert L. Santos, director from 2022 to 2025; Thomas Mesenbourg Jr., acting director in 2012-13; Robert Groves, director from 2009 to 2012; James F. Holmes, acting director in 1998; and Marty Farnsworth Riche, director from 1994 to 1998.

Their main objection is to how the rule would decide where people live. Since 1790, the census has counted people at the place where they live and sleep most of the time as of Census Day, which has been April 1 since 1930. The proposed rule would instead count people where they "lawfully spent the greatest number of days" between January 3 and April 1, and would require that residence to be consistent with federal tax records such as income tax returns, W-2s, and 1099s.

That would make some people harder to count, the directors wrote, naming college students, gig workers, snowbirds, and people who move. Respondents could also be confused when the place they spent the most days differs from the one on their tax records, which they said "will surely occur" for students and snowbirds.

The letter, drawing on former Internal Revenue Service statistics director Barry Johnson, lists problems with using tax data to decide residence:

• Tax records don't cover everyone, especially children.
• The address on a tax record may be a post office box, a business, a tax preparer's office, or a military mailing address.
• Tax deadlines don't line up with the census. People file after Census Day or get extensions until October, while state totals for House seats are due December 31. In a 2020 simulation, 3.7 million 2019 tax returns covering 5.2 million people were not available in time.
• Matching records is imperfect. A 2023 report could not link nearly 6 million IRS records, about 2.7 percent, to census files.

"Tax records are designed to administer the tax system, not to determine a person's usual residence," they wrote. The directors said tax data should stay one input among several, as it was in 2020, and that conflicting records should prompt more review instead of the rejection of a census response.

Before changing residence rules, they said, the department should run end-to-end testing, measure the effects on coverage and duplication, publish the results, and let outside experts review them. They also asked how the bureau would protect confidential tax information and handle complicated living arrangements, such as families sharing a home or people renting part of a house.

The directors' letter centers on the residence rules, but they wrote that those changes, combined with the rule's other changes to census content, lead them "to strongly oppose all changes described in the Federal Register." The proposal would also leave noncitizens without green cards out of the count used to divide House seats and bar questions about race, ethnicity, and sexual orientation.

The comment period closed November 2 with 143,238 comments on the docket. Other opponents include city and state officials, tribal leaders, and college associations. The bureau must now decide whether to finalize, revise, or withdraw the rule.

Sources

Ron Jarmin, Robert L. Santos, Thomas Mesenbourg Jr., Robert Groves, James F. Holmes, and Marty Farnsworth Riche, "Proposed & Untested Changes to 2030 Census Residence Rule Risk the Accuracy of the Count," public comment, October 28, 2026, as posted by The Census Project. U.S. Department of Commerce and U.S. Census Bureau, proposed rule, Federal Register document 2026-18481, September 10, 2026. Comment count from docket USBC-2026-0628 as reported by the Federal Register on November 3, 2026.