Open Letter to Census Director Cook re: Proposed Changes
This is a letter I submitted to Regulations.gov regarding their obnoxious new proposed rule posted on Sep, 10, 2026: Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions (USBC-2026-0628-0001)
Letter Sent 11/1/2026:
Dear Director Cook,
I was provided a form letter from the National League of Cities, but I'm writing this directly because what I have to say is important.
I am a long-time resident of Michigan, and independent software developer. I have a Master’s in City Planning from MIT, and I used to work for Southeast Michigan Council of Governments (SEMCOG) as a Planning Analyst.
At SEMCOG, I personally created a report of 100 years of population growth in the Detroit Metropolitan Area. To create this report, I used Census data from 1900 to 2000, going to the Wayne State Library to get older Census books. My report was funded by the Detroit Water and Sewerage Department (DWSD), and was published by SEMCOG on their website for the benefit of the public and DWSD.
After learning in-depth about how the Census works through the process of gathering this data, I developed a great admiration and respect for the bureau. It was the consistency of process, adherence to the Constitution, and resolute support of the public good that were the most remarkable. It built my faith in the Government of the United States.
My report relied *entirely* upon the *continuity* of the population counts for each MCD (minor civil division), and this is why the proposed changes are absolutely outrageous to me! My report would have never been possible had the definition of residence and ‘person’ changed over time. I am very saddened to think about how the future historical report of population from 2000 to 2100 will be rendered impossible by this change, and how many other data series will be trashed.
The Constitution’s Enumeration clause states, “Representatives and direct Taxes shall be apportioned among the several States which may be included within this Union, according to their respective Numbers, which shall be determined by adding to the whole Number of free Persons…” The key word here is “Persons,” which means any person residing in the territory of the United States. The meaning of “Persons” is clear and consistent throughout the Constitution and all subsequent law. To abrogate this is about the stupidest policy that anyone could ever think of. I would really like to know whose idea this was, and what their intentions were, because they certainly did not have the American public’s interest in mind!
The other aspects of this proposal are equally stupid. Any change that would intentionally under-count persons, or omit information critical to good governance, will directly undermine the great public benefit and value that the Census provides to our country.
I want the Census to remain a respected, admired, and trusted source of population data for the next 100 years. I’m begging you, please do not enact any of these dangerous and harmful proposed changes!
Sincerely,
Shailesh Humbad
Michigan Resident
P.S. I attached the report and unpublished technical documentation to this submission.
Charts Derived from Accurate, Historical Census Data
Detroit Population History 1900-2000 Web Page - Link to my old web page with more information
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