Appendix E: Proposed FOIA and Document Requests

Many of the most consequential 2030 Census decisions will be documented in materials that do not automatically appear in the Operational Plan or Memorandum Series. Targeted document requests can help reveal how broad commitments are being translated into rules, requirements, data standards, and system designs.

The requests below are intended as a starting point. They are not exhaustive, and they should generally be narrowed to a specific decision, document type, office, and time period before filing.

Where possible, advocates should first seek voluntary disclosure through Census briefings, congressional requests, stakeholder meetings, or direct requests for particular documents. FOIA is most useful when those avenues do not produce the records needed to understand an important decision.

Broad requests for “all records relating to the 2030 Census” are unlikely to be efficient. A stronger approach is to request the documents that show what rule was adopted, what evidence supported it, who approved it, and when it became operationally binding.

1. In-Office Enumeration Specifications

Priority: Very high

Advocates should seek the documents that define when Census may complete a housing unit through In-Office Enumeration rather than continued direct contact.

Priority records include:

  • current business and operational requirements for IOE;

  • eligibility criteria and decision rules;

  • minimum contact requirements before IOE;

  • administrative-data sufficiency thresholds;

  • rules distinguishing occupancy, household size, person placement, and characteristic completion;

  • model specifications or scoring rules used to recommend IOE;

  • exception and override procedures;

  • quality-control requirements;

  • validation studies;

  • briefing or decision memoranda approving the rules; and

  • changes made following the 2026 Census Test.

A useful request should distinguish current production or test specifications from earlier brainstorming. Advocates should also consider requesting prior versions so changes can be traced over time.

Key question the records should answer: What, precisely, must happen before Census decides that direct enumeration can end and administrative enumeration can take its place?

2. Person Characteristic Frame Quality Standards

Priority: Very high

The PCF will support matching, household reconstruction, and IOE, making its quality standards central to several 2030 operations.

Priority records include:

  • quality requirements for inclusion in the PCF;

  • documentation of source-specific quality measures;

  • thresholds for linking people to addresses;

  • household-composition rules;

  • standards for individual characteristics;

  • data-source approval memoranda;

  • validation results by population and geography;

  • documentation of known source limitations;

  • quality or confidence scores attached to PCF records;

  • procedures for resolving conflicting sources;

  • requirements governing use of PCF information in IOE; and

  • privacy, access-control, and auditing requirements.

Requests should seek differential quality assessments, not merely overall accuracy or match rates.

Key question the records should answer: What evidence allows Census to conclude that a PCF record is reliable enough for each use to which it is put?

3. Internal Memoranda of Agreement

Priority: High

The 2030 program relies heavily on capabilities provided by other Census components. Internal Memoranda of Agreement can clarify responsibilities that are difficult to see in public planning documents.

Priority agreements include those governing:

  • administrative and supplemental data;

  • the Demographic Frame and Person Characteristic Frame;

  • geographic and address-frame services;

  • enterprise data-collection systems;

  • response processing and matching;

  • IT infrastructure;

  • disclosure avoidance;

  • cybersecurity;

  • Coverage Estimation;

  • research and evaluation support; and

  • other enterprise services essential to the decennial census.

Advocates should seek the agreement itself, amendments, service-level requirements, performance measures, delivery schedules, and escalation procedures.

Key question the records should answer: Which Census component is responsible for each critical 2030 capability, what must it deliver, and what happens if it does not meet the decennial program’s requirements?

4. Program Architecture and Requirements

Priority: Very high

Program Architecture may provide the clearest view of how the 2030 Census actually works beneath the narrative Operational Plan.

Priority records include:

  • current Program Architecture diagrams and descriptions;

  • business-process models;

  • data-flow diagrams;

  • operational interfaces and dependencies;

  • business requirements;

  • operational requirements;

  • requirements traceability matrices;

  • system-to-operation mappings;

  • change-control records; and

  • architecture review or approval materials.

Requests can be narrowed to particular operations such as IOE, PCF Management, Response Processing, Coverage Estimation, Language Services, or In-Field Enumeration.

Security-sensitive portions may legitimately require redaction. Advocates should nevertheless seek the segregable material needed to understand operational rules, dependencies, and decision points.

Key question the records should answer: How have the broad commitments in the Operational Plan been translated into requirements that systems and contractors must actually implement?

5. Research-Review Recommendations and Disposition

Priority: High

Census completed a large body of early 2030 research before publishing Baseline 1. Advocates should seek the record showing how that research became the operational design.

Priority records include:

  • final recommendations from Design Selection Phase research projects;

  • compilations of preliminary recommendations;

  • materials prepared for research-review or design-review meetings;

  • recommendations presented to senior program leadership;

  • scoring or prioritization criteria;

  • meeting agendas and presentation materials;

  • decision summaries;

  • records identifying recommendations accepted, modified, deferred, or rejected;

  • rationales for those dispositions; and

  • subsequent research assigned to unresolved questions.

Where feasible, requests should identify specific Enhancement Areas or research projects rather than seeking every research document at once.

Key question the records should answer: Which research recommendations shaped Baseline 1, which did not, and why?

6. Disclosure Avoidance Planning

Priority: Very high

The Commerce prohibition on noise infusion fundamentally changed the disclosure avoidance research program. Advocates should seek documentation of the transition from the original plan to the replacement approach.

Priority records include:

  • analyses of the Commerce DAO’s application to the 2030 Census;

  • inventories of disclosure avoidance methods considered permissible;

  • evaluations of suppression, coarsening, rounding, aggregation, or other alternatives;

  • product-by-product risk assessments;

  • analyses of impacts on geographic and demographic detail;

  • internal research plans and schedules;

  • revised milestone and demonstration-data plans;

  • legal and policy reviews;

  • technical recommendations to Census or Commerce leadership;

  • decision memoranda;

  • records identifying rejected alternatives and reasons for rejection; and

  • correspondence concerning changes to the original 2030 disclosure avoidance research agenda.

Because this work may evolve rapidly, advocates should consider sequenced requests rather than a single request covering the entire decade.

Key question the records should answer: What methods is Census actually considering, what data products would each permit, and how did Commerce policy constrain the scientific options?

7. Language-DAO Implementation Guidance

Priority: Very high

Advocates should seek the documents showing how Commerce and Census interpret the English-language policy for the decennial census.

Priority records include:

  • formal guidance from Commerce to Census;

  • Census legal or policy analyses of the DAO;

  • requests for exemptions, exceptions, or determinations;

  • decisions identifying which multilingual services may continue;

  • analyses of operational or data-quality effects;

  • proposed changes to questionnaires, CQA, IVR, mailings, field support, translated materials, or partner communications;

  • cost and staffing analyses;

  • communications between Census leadership and Commerce concerning implementation; and

  • decision memoranda documenting changes from Baseline 1.

Requests should distinguish policy guidance from deliberative drafts where possible. A request for the final or currently operative guidance is often more useful than a broad request for every discussion of language access.

Key question the records should answer: What does Census believe it is permitted or required to do under the Commerce policy, and which parts of the planned Language Program are at risk as a result?

Sequencing the Requests

The highest-value requests should be tied to the calendar in Appendix B.

Through Baseline 2

Prioritize:

  1. IOE rules and requirements.

  2. PCF quality standards and source assessments.

  3. Research-review recommendations and dispositions.

  4. Language-DAO implementation guidance.

  5. Current disclosure avoidance replacement planning.

  6. Requirements and architecture for operations already entering system development.

The purpose is to obtain the documents while the design is still being refined.

Before the 2028 Dress Rehearsal

Follow up with requests for:

  • updated IOE and field-contact specifications;

  • final or near-final operational requirements;

  • Dress Rehearsal test plans and readiness reviews;

  • revised language procedures;

  • disclosure avoidance demonstration plans;

  • Coverage Estimation specifications;

  • major changes to Program Architecture; and

  • records explaining departures from Baseline 2.

At this point, comparing versions becomes especially valuable. A requirement that changed between 2026 and 2028 may reveal more about the design than either version alone.

During Final Design and Production

Requests should become more selective and faster-moving. Priority records may include:

  • late policy or operational changes;

  • waivers and exceptions;

  • readiness findings;

  • risk escalations;

  • contractor or system failures;

  • changes in field staffing or contact rules;

  • decisions responding to funding constraints; and

  • leadership directives that alter tested procedures.

Advocates should avoid waiting for a comprehensive retrospective request when a particular late change may require immediate oversight or litigation.

Drafting Better Requests

A strong request will usually specify:

The decision. Identify the rule or issue being investigated.

The documents. Ask for requirements, decision memoranda, assessments, recommendations, approvals, or other identifiable record types.

The relevant offices. Where known, identify the Census program, division, or Commerce office most likely to maintain the records.

The time period. Tie the request to the research, testing, or decision window.

Versions. Where changes matter, request both the current version and superseded versions.

Attachments and referenced documents. Ask for materials incorporated into or relied upon by the requested memorandum or decision.

Final and operative records first. Request final guidance, approved requirements, and adopted decision documents explicitly. Draft material can be valuable, but the first objective is often to establish the rule Census is actually using.

Advocates should also ask Census to provide reasonably segregable portions of records containing protected information rather than withholding an entire document because some sections are exempt from release.

Beyond FOIA

Some of the most useful records may be easier to obtain through other forms of oversight.

Congressional committees can request internal studies, requirements, risk records, and decision memoranda directly. GAO can examine program management, cost, acquisition, and methodological risks. State and tribal governments may be able to obtain operational information through established Census relationships. Researchers and stakeholder organizations can request technical briefings or publication through the Memorandum Series.

Advocates should therefore treat this appendix as a document-acquisition agenda, not simply a FOIA list.

The objective is to obtain the evidence behind consequential decisions while that evidence can still inform advocacy. A document released in 2031 may be invaluable for historical accountability. The same document released in 2027 may help change the census.

****