Public Comment on Proposed Changes to the Decennial Census

Below, please find the public comment letter we will be submitting regarding the proposed Census changes. The deadline is fast approaching, only 5 days remain. If you would like to join us in opposing these changes, click here to sign on to our letter.


Re: Opposition to Proposed Revisions Removing Race and Ethnicity Categories and Adding Citizenship Measures to the Decennial Census

1. Introduction & Statement of Opposition

The AfroLatin@ Forum and the Afro-Latino Coalition, along with the below signatories, write to express our strong and unequivocal opposition to proposed administrative changes to the national decennial Census. These proposals, which reportedly seek to remove essential race and ethnicity categories and impose citizenship-related inquiries, undermine the foundational mandate of the enumeration.

Article I, Section 2 of the U.S. Constitution requires a complete count of all persons residing in the United States, regardless of legal status or citizenship. Excluding or deterring non-citizens, including immigrants without permanent legal residency, violates this constitutional requirement. Furthermore, attempting to exclude or diminish the presence of non-citizen populations echoes painful eras in our nation’s history when certain human beings were deliberately not counted fully or equally under racist doctrines. We firmly reject any proposal that seeks to regress to a system where certain residents are treated as invisible.

2. Undercounting Afro-Latino Communities and the Impact of SPD 15

Our coalition has long-raised concerns regarding how demographic questions are structured, including changes under Statistical Policy Directive No. 15 (SPD 15). Combining or simplifying race and ethnicity questions without proper nuance creates widespread confusion among multi-identity populations.

Afro-Latinos represent a uniquely vulnerable demographic in data collection. While official Census estimates have previously placed the Afro-Latino population at roughly 1 million, independent sociological and demographic research estimates the actual population to be upwards of 6 million or more. Removing race and ethnicity measures altogether, compounded by citizenship inquiries, will multiply fear and confusion, weaken community trust, and guarantee an unprecedented undercount of Afro-Latino people.

3. Financial Contributions and Legal Mandate

Determination of "legality" or legal status is not, and has never been, a prerequisite for being counted in the decennial Census. Immigrants without green cards and non-citizen residents live in our communities, contribute labor, pay state, local, and federal taxes, and fuel local economies.

Census data directly governs congressional apportionment, civil rights protections, and the equitable distribution of federal funding. Depriving communities of the ability to accurately reflect all their residents:

  • Punishes Local Communities: Cities and neighborhoods with high immigrant populations will be systematically deprived of federal resources that their residents' economic and tax contributions help generate.

  • Distorts Political Representation: Suppressing participation through citizenship questions or racial erasure artificially diminishes political representation for minority and immigrant-heavy districts.

Obstructs Civil Rights Enforcement: Federal agencies rely on objective demographic data to enforce civil rights, ensure fair housing, and monitor compliance with anti-discrimination laws.

4. Call to Action: Reject "Race-Blind" Policies and Exclusions

We strongly urge the Census Bureau and the OMB to reject "race-blind" theories and citizenship-based exclusions. Ignoring race or chilling participation among non-citizens does not foster unity, it obscures systemic inequality and deprives local jurisdictions of vital resources.

Instead of creating barriers that decrease participation, administrative policies must make the Census simpler, more inclusive, and safer for all residents to complete. We urge the Census Bureau to:

  1. Maintain robust, distinct, and clear measures for both race and ethnicity.

  2. Uphold the constitutional mandate to count every resident, regardless of citizenship or legal status.

  3. Consult directly with sociologists, demographers, and community advocates who specialize in Afro-Latino and immigrant research to ensure survey instruments accurately reflect lived realities.

If the United States is truly committed to equal justice and equitable treatment under the law, it must count every person who makes up our nation and rely on accurate statistics to improve our society.

Signatories

  • Amiyra Alveranga

  • Judith Anderson, BMCC

  • Veree Brown

  • Tatiana Bryant

  • Leah Burns

  • Ife Changa

  • Gabrielle Civil, Professor, California Institute of the Arts

  • Kay Coates

  • Larisa Correa, Founder and Owner, Mpower Counseling, PLLC

  • Dr. Aisha Cort Hamilton, Bucknell University

  • Cecelie Counts

  • Sharon Cruz, Executive Director, Afro-Latino Education and Arts Collective

  • Christina Davidson, Professor, USC

  • Tanya Davis-Castro

  • Omar Eaton-Martinez

  • Zulekha Foulen

  • Dr. Mariluz Franco

  • Sita Frederick

  • William Garcia-Medina, Professor, UC-Blue Ash

  • Rev. Dr. Cheryl Green

  • Nathaniel Harvey

  • Dr. Marcus Johnson, Ujima People's Progress Party

  • Keisha Katz

  • Michael Lopez

  • Diana Lugo-Martinez

  • Nancy López, PhD Sociology

  • Yalidy Matos, Associate Professor

  • Manuel Mendez, President, DC AfroLatino Caucus

  • Zenaida Mendez, President, National Dominican Women's Caucus

  • Eliana Mercedes

  • Marisol Negron, Associate Professor of American Studies and Latino Studies, University of Massachusetts Boston

  • Francis Pena

  • Maria Ponciano, Teacher, NYCPS

  • Suzanne Ricco-Lightfoot

  • Bonnie Richardson

  • Vitalina Robinson

  • Obrian Rosario, J.D.

  • Liz Schnee

  • Nick Shaw

  • Daniel Shaw-Vicente

  • Maya Simpkins

  • John Thomas III, Editor, The Christian Recorder

  • Melissa Valle, Associate Professor of Global Racial Justice, Rutgers University-Newark

  • Mari Vicente

  • Brandi Waters

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