On September 10, 2026 the Census Bureau proposed rules that would change who gets counted in the 2030 Census, where they get counted, and what questions get asked.
- The first set of proposed changes would redefine the residence criteria determining who is included in the population apportionment.
- The apportionment count would be limited to only include U.S. citizens and lawful permanent residents (also known as green card holders)
- Usual residence would be defined as the time window from January 3 to April 1 of the Census year.
- The second set of proposed changes would prohibit data collection for race and ethnicity in the decennial questionnaire.
The Census Bureau is accepting comments on this proposed rule until November 2, 2026.
Submit your comment
SEMCOG relies extensively on U.S. Census Bureau data for population and household forecasting, transportation planning and modeling, housing and land use analysis, infrastructure planning, and understanding demographic change in the seven-county region it serves. SEMCOG also provides Census data, Census-derived analysis, and technical assistance to local governments throughout Southeast Michigan, helping communities make informed planning and policy decisions.
These proposed changes could undermine the accuracy, consistency, and level of detail of Census data used to represent the populations served by SEMCOG and local governments. For these reasons, SEMCOG opposes the proposed rule changes to the 2030 Census.
SEMCOG Comment LetterSummary of Proposed Changes
| Criteria | Current/2020 Approach | New Proposal |
| Foreign citizens living in the United States | Foreign citizens “living in” the U.S are included at usual U.S. residence for apportionment, regardless of immigration status; Foreign citizens “visiting” U.S. such as on vacation or business travelers are excluded | Only U.S citizens and lawful permanent residents will be included in apportionment. Foreign born individuals with legal work visas, international students, recognized refugees and asylees would be excluded |
| Usual residence | Where a person lived and slept most of the time during the year | Where a person spent the greatest number of days during the January 3 – April 1 enumeration period. |
| Race and ethnicity questions | Included in the 2020 Decennial Census questionnaire | Excluded from the Decennial Census 2030 questionnaire |
| Are the rules final? | Current census practice remains in place while 2030 planning continues This is a proposed rule open for comments, it is not yet operative. Based on the comments, the Bureau may revise, finalize, or withdraw the proposal. |
Impacts of Proposed Changes
1. Residence Criteria
Undercounts community needs: The proposed residence criteria would create a disconnect between Census population counts and the population actually living in and generating demand within communities. States, Metropolitan Planning Organizations (MPOs), and local governments must account for all residents when planning transportation systems, housing, infrastructure, emergency services, and other public services. Excluding certain residents from Census population measures could therefore understate the population that communities must serve and create inconsistencies between allocated resources and the actual need.
Impacts regional and long-term planning: Changes in who is included in the Census population could also disrupt historical comparability. SEMCOG uses decennial Census results as benchmarks for regional population and household forecasts, long-term demographic analysis, and regional transportations plan, a federally required long-term blueprint of a region’s transportation system. Changes in the population universe could make it more difficult to distinguish actual demographic trends from changes resulting from Census methodology.
Funding Impacts for States, MPOs, and Local Governments: Census population counts and subsequent annual population estimates are used to determine eligibility and allocations for numerous federal and state programs, including transportation funding and state revenue sharing. For example, urbanized-area population is used in the suballocation of certain federal transportation funds. An undercount could therefore result in states, MPOs, and local governments receiving fewer resources while still being responsible for planning for and serving their full populations. Because the decennial Census establishes a population benchmark for the following decade, an undercount could have cumulative funding consequences for years, reducing resources available for transportation, infrastructure, and essential community services.
Replacement of the established usual-residence standard: The proposed rule would generally assign a person’s residence based on where the person was lawfully present for the greatest number of days during a fixed January 3–April 1 enumeration period, rather than on the longstanding standard of where the person lives and sleeps most of the year. This change could have significant implications for Michigan communities, particularly those with “snowbird” retirees who spend winters in warmer southern states but maintain their primary residences in Michigan and rely on local services for much of the year.
2. Restrictions on Inclusion of Demographic Questions
The second part of the rule would restrict race and ethnicity questions on the decennial Census questionnaire. For SEMCOG, detailed demographic information is essential for understanding how population characteristics and needs vary across communities and neighborhoods.
Implications for Transportation and Regional Planning: SEMCOG uses demographic data for transportation and accessibility analysis, travel demand modeling, population forecasting, housing and neighborhood analysis, school resource planning, community engagement, corridor planning, and evaluation of transportation investments and community impacts. Race and ethnicity data are particularly important for small-area analysis and for understanding differences in transportation needs and access to opportunities across the region. Not having these detailed data would limit our ability to develop comprehensive transportation and economic development plans.
Impacts on Local Governments: Local governments rely on detailed demographic data to understand neighborhood change, assess housing and infrastructure needs, plan public facilities and services, develop comprehensive and master plans, and support federal and state grant applications. Reducing the availability or reliability of these data could increase the analytical and financial burden on local governments.
Implications of the Combined Changes
For an MPO such as SEMCOG, an accurate population count is fundamental, but the value of the decennial census extends beyond the total population count. Detailed demographic information allows SEMCOG to understand not only how many people live in Southeast Michigan, but also where different populations live and how demographic characteristics vary among communities and neighborhoods.
Decennial Census counts and demographic data are the foundation for a wide range of federal, state, local, and private data products, including annual population estimates, American Community Survey estimates, and other surveys. Changes to the decennial Census would affect the accuracy, consistency, and reliability of every product that uses it as a baseline because the census data informs survey weighting, sample design, and broader statistical modeling. SEMCOG relies on these products to support regional planning and provide data and technical assistance to its member communities.
An inaccurate 2030 Census could result in states and communities receiving fewer federal resources while still serving their full populations. Because Census counts influence funding decisions throughout the following decade, an undercount could compound into significant cumulative funding losses—leaving communities to meet the same transportation, housing, infrastructure, and service needs with fewer federal dollars.
The proposed rule provides a 33-day comment period for consequential changes to apportionment, residence criteria, questionnaire content, and data production. That period is inadequate for rigorous analysis by state, regional, local, and community stakeholders to assess the proposal and provide meaningful input.
For all the above-mentioned reasons, SEMCOG opposes the proposed rule changes to the residence criteria and demographic data collection for the 2030 Census outlined in the Federal Register “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions” (FDMS Docket Number USBC-2026-0628, published September 10, 2026)
SEMCOG also encourages elected officials, local governments, and other stakeholders to submit comments to the Federal Register through Regulations.gov by November 2, 2026.
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