Denver, CO – Re: “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions” (Docket No. 260903-0005; RIN 0607-AA75)
Dear Mr. Sweeney:
The Denver Foundation is writing to oppose the Department of Commerce and the Census Bureau’s proposed rule published on September 10, 2026, titled Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions (Docket No. 260903-0005).
As a community foundation in Denver, Colo., accurate and complete data is essential to us and the communities we serve and have been serving for more than 100 years. Over the past century, we have distributed $1.9 billion to support community initiatives, ensuring our dollars go to the areas most in need. To do that, we need accurate and complete data.
These proposed changes will lead to a loss of important data that we rely on. Without it, we will be unable to focus our grantmaking or advise our fundholders on how to direct their giving to make the greatest impact. Inaccurate or incomplete data hurts strategy development, planning, research, evaluation, and more, and excluding broad groups of people from the census count harms everyone. This loss of data will also hurt our ability to evaluate the outcomes of our work, and coordinate with our partners.
The proposed rule would exclude the following from the count: temporary workers, international students, refugees waiting for permanent residence, and individuals with other temporary or humanitarian immigration status. Such undercounts risk resource shortfalls for local infrastructure, schools, hospitals, roads, and social safety net programs- which impact all our residents in our communities.
Given the above concerns, The Denver Foundation respectfully requests that both parts of the proposal published on September 10 be withdrawn.
Thank you for your consideration of this request.
Sincerely,
Javier Alberto Soto, President & CEO, The Denver Foundation
The Census impacts all of us. Please consider submitting your own comments to protect a fair, complete, and accurate 2030 census by Nov. 2 via the Federal e-Rulemaking Portal: https://www.regulations.gov/commenton/USBC-2026-0628-0001. To learn more about the changes, visit the Council on Nonprofits.
