On November 2, 2026, the Environmental Protection Network (EPN) submitted formal comments urging the U.S. Census Bureau to withdraw its proposed rule that would change how people are counted in the decennial census and would restrict the collection of demographic information, including race and ethnicity.
Our comments explain how these changes could undermine the accuracy and reliability of census data that federal, state, Tribal, and local agencies rely on to protect public health, distribute environmental funding, and implement environmental laws.
EPN’s comments establish four central findings:
- Accurate population counts are essential to fair representation and effective government. The Constitution requires the census to count all persons residing in the United States, regardless of citizenship status. EPN argues that excluding certain noncitizens from population counts conflicts with this requirement and could produce significant undercounts. Proposed changes to how the Census Bureau determines a person’s usual residence could also create confusion and inaccuracies, particularly for people who move frequently, travel for work, or lack permanent housing.
- Reliable census data helps ensure environmental funding reaches communities where it is needed. Population information informs federal funding decisions for drinking water infrastructure, state air and water pollution control programs, pesticide enforcement, and contaminated-site cleanup. The comments identify specific statutory requirements that rely on population and demographic information, including Clean Air Act grants, Drinking Water State Revolving Funds, and Brownfields grants. Inaccurate counts or incomplete demographic information could distort funding allocations, weaken program effectiveness, and make it harder for EPA and its partners to fulfill their responsibilities under environmental laws.
- Sound environmental policy depends on reliable data and established scientific practices. Collecting demographic information enables agencies to evaluate program effectiveness, identify emerging public health concerns, and ensure that federal environmental and civil rights laws are implemented effectively. EPN argues that the Census Bureau has not provided sufficient evidence that restricting demographic questions is necessary to protect privacy or improve response rates. The proposed changes instead risk undermining the quality and consistency of information that government agencies, researchers, and communities have relied on for decades. Further, detailed demographic information helps agencies understand how pollution exposure intersects with poverty, limited healthcare access, housing insecurity, and other factors that influence health. Without this information, communities experiencing multiple environmental burdens can remain hidden within broader population averages.
EPN’s comments emphasize that accurate population counts and detailed demographic information are essential to effective, evidence-based protection of human health and the environment.