Submitting comments to the Census Bureau regarding their proposed residence rules

Talking points and submission instructions for comments to respond to the Census Bureau's proposal to count incarcerated people in the wrong place in 2020.

by Aleks Kajstura, July 1, 2016

UPDATE: Deadline extended to September 1.
The Census Bureau has extended the deadline to submit comments to September 1, 2016, explaining: “Because of the scope of the proposed criteria, and in response to individuals and organizations who have requested more time to review the proposed criteria, the Census Bureau has decided to extend the comment period for an additional 31 days.”

The U.S. Census Bureau released its proposed 2020 Census ‘residence rules’ that ignore overwhelming public input supporting a change in how incarcerated persons are counted in the Census. The Bureau announced it is leaving in place the inaccurate and outdated practice of counting incarcerated persons as "residents" of the prison location instead of their home communities. Interested stakeholders have until August 1 to submit comments before this proposal becomes final.

We’ve released our statement on these developments, and we’re working on our comment to the Bureau now, but it would be useful for the Bureau to hear from a diverse coalition of people. There are an impressive variety of reasons why the Bureau’s proposal to count incarcerated people at the location of the facility where they happen to be located on Census day is wrong and needs to be changed.

Here are a couple of talking points you can use to get started:

  • The Census Bureau is wrong to consider incarcerated people as residents of the correctional facility because [insert your own reason why people do not “live” in the prison.]
  • The Bureau has chosen to continue counting people in the wrong place, ensuring an inaccurate 2020 Census. [Describe how that impacts your community (counting incarcerated people as if they were “residents” of the correctional facility makes the Census less accurate for everyone: rural and urban communities; incarcerated persons and their families; governmental authorities trying to draw accurate redistricting plans; researchers trying to understand the demographics of local communities)]

Written comments regarding the proposed “2020 Census Residence Rule and Residence Situations” can be emailed by August 1 to Karen Humes, Chief, Population Division at

If you submit a comment letter to the Bureau, we’d greatly appreciate it if you could please forward a copy to us at

You can also snail mail comments, but based on our experience with the Census Bureau and other federal agencies we strongly recommend using email. And if you need help putting together a comment letter with facts for your state, explore our website or contact us.

3 responses:

  1. Marsha Kidd says:

    This process is deceiving and a god example of “criminal thinking,” at it’s best. It needs to stop.

  2. Garry Mendez says:

    I don’t understand the original rationale for this policy. Could you direct me to source. I mean I know why they do this but I don’t understand how they pulled it off.
    To me this seems to reinforce that we have a one party system that is working for the interest of the haves.

  3. LC in Texas says:

    Prisoners have family and homes, especially American prisoners. They know where they call home and that is where their vote should be counted. When a prisoner is kept on the road moving from prison to prison, how can this be called their place of residence?

    Furthermore, once a prisoner has been discharged from prison – they are back in society and should have voting privilege. In my opinion: our administration needs to be in prison and not allowed to vote!

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