Pago Pago, AMERICAN SAMOA — New regulations proposed by the U.S. Census Bureau could deepen longstanding data inequities affecting people in U.S. territories, according to a comment submitted by Right to Democracy, a non-profit that works to advance democracy, equity, and self-determination in U.S. territories. 

The proposals would change how the Bureau determines residence and would restrict demographic questions in the decennial census.

“These sweeping rule changes don’t even mention the U.S. territories or explain how they will impact people that live here. Our jurisdictions already face data challenges related to Census counting, and these changes create even more dangerous uncertainty that will lead to the further invisibilisation of our communities," said Adi Martínez-Román, Co-Director of Right to Democracy.

“Weakening the data our communities need to advocate for resources and document discrimination institutionalizes our exclusion. The Census Bureau must account for the people and realities of American Samoa, Puerto Rico, The U.S. Virgin Islands, the Northern Mariana Islands and Guam before changing how it counts us,” he stated.

Announced on September 10, the new proposals would prohibit questions about race, ethnicity, and sexual orientation on the decennial census questionnaire. They would also establish new residence criteria for congressional apportionment, including reliance on tax records and a January 3– April 1 reference period. And they would exclude certain noncitizen residents from the apportionment count. The public comment deadline was November 2, 2026.

Right to Democracy’s comment emphasizes the consequences of removing racial and ethnic questions for communities already underserved by federal statistics. 

“Eliminating questions about race and ethnicity would remove a key source of detailed information about Puerto Rican communities in the states and about Afro-Boricua and other racial identities within Puerto Rico,” explained Martínez-Román. 

Although the proposals would allow demographic questions to continue in the American Community Survey (ACS), Guam, American Samoa, the Northern Mariana Islands, and the U.S. Virgin Islands are excluded from the ACS altogether, exacerbating the impact these changes will have on these communities. 

The comments also raise concerns about residence criteria that do not address territorial tax systems. Many territorial residents file income tax returns with their local governments rather than the IRS. The proposals do not specify how those returns would be recognized, creating uncertainty about how territorial residents would be treated. The new reference period also raises questions about how the Bureau would account for people temporarily displaced by disasters or moving between territories and the states.

Right to Democracy is also seeking clarity about the treatment of U.S. nationals from American Samoa living in the states. U.S. nationals are not foreign nationals, and the Bureau should expressly confirm their inclusion rather than leave communities to navigate uncertainty about rules framed around citizenship and immigration status.

“Rather than taking steps to further exclude people from U.S. territories, the Census should be taking steps to close the data gaps that have long harmed our communities,” said Neil Weare, Co-Director of Right to Democracy. “Federal rules that overlook these communities can deepen inequities that already exist. People in the territories deserve accurate data that reflect their lives and needs.”

“Structural and political erasure begins with data erasure. Data equity is a fundamental civil right. By altering how we define residency and capture demographic realities in 2030, the Census Bureau risks rendering our communities structurally invisible. For Puerto Rico and the territories, these changes aren't just administrative hurdles. They dictate our access to resources and our political visibility. We must ensure every territorial resident is accurately counted, because data equity is the absolute baseline for true democratic representation,” said Lianeris Estremera Rodriguez, a public health researcher and member of Right to Democracy’s Cross-Territorial Coalition, who contributed to the research on the impacts of the proposed changes.

“Public services, disaster recovery, and community investment all rely on accurate census data. Losing detailed demographic information would disproportionately impact communities of color, making it more difficult to identify racial disparities, enforce civil rights protections, and demonstrate unmet needs. Territorial residents’ exclusion from congressional apportionment does not diminish their need for a complete census and reliable demographic information,” said Marlee Sonico, a CHamoru legal scholar and member of the Cross-Territorial Coalition, who contributed to the research.

Right to Democracy urges the Census Bureau to withdraw the proposals and work directly with territorial communities to improve data collection. 

Editor’s Note: American Samoa’s current population census count has been an ongoing debate, with the Territory’s leaders citing undercounting by the census. 

The official U.S. Census Bureau count for American Samoa from the 2020 Decennial Census is 49,710 residents, with the Population Change: a 10.5% decrease from the 2010 Census count of 55,519 residents. Local leaders estimate the population at around 51,000+ (at least).

Local leaders argue that the 2020 federal count was fundamentally flawed due to unique local disruptions: 

    •    COVID-19 Lockdowns: The house-to-house interviewing process was halted for roughly three months due to strict local pandemic restrictions. 
    •    Stranded Residents: Because of pandemic border closures, a significant portion of American Samoa's population was stranded outside of the territory when the census took place. 
    •    Immigration & Mistrust: Local tracking noted that some residents avoided census workers or refused to participate due to fear regarding their immigration statuses or a general mistrust of how the data would be managed. 
  
Because federal grant funding and resource allocations are directly tied to these formulas, local leaders continue to emphasize that a sub-50,000 count misrepresents the real demand on the territory's infrastructure and public services. 

More recent international tracking models, like those from Worldometer and the United Nations, project that the island's population has since drifted down toward the mid-40,000s due to ongoing outmigration to the U.S. mainland.