George M. Cook
Deputy Under Secretary, Office of the Under Secretary for Economic Affairs
U.S. Census Bureau 4600 Silver Hill Road Suitland, MD 20746
Re: “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions” (RIN 0607-AA75; Docket No. USBC-2026-0628)
Dear Deputy Under Secretary Cook:
On behalf of the National LGBTQ+ & Allied Chamber of Commerce (NGLCC) and our undersigned affiliate chambers, we write to express our concern regarding the Census Bureau's proposed regulation that would prohibit the collection of sexual-orientation and gender-identity information through questionnaires used to enumerate the population. We respectfully urge the Bureau to refrain from adopting a categorical restriction until it demonstrates that alternative data sources can provide information of comparable quality, reliability, and utility regarding sexual orientation and gender identity for businesses, policymakers, researchers, and communities across the United States.
NGLCC's affiliate chambers collectively represent thousands of LGBTQ+-owned businesses and allied companies operating in communities across the country. Our members contribute to local economies, create jobs, expand supplier networks, and drive economic growth. Accurate demographic data, including information regarding sexual orientation and gender identity, help businesses understand the markets they serve, identify growth opportunities, and make informed decisions about investment and expansion.
Economic Value of Sexual-Orientation and Gender-Identity Data
This proposal has economic consequences. Sexual-orientation and gender-identity data are not merely demographic statistics; they are market intelligence used by businesses to make real-world decisions about investment, hiring, expansion, advertising, and customer engagement. Commercial data providers already collect and model these characteristics because businesses demand insights regarding LGBTQ+ consumers, entrepreneurs, and workforces.
Research conducted by the WIPP Education Institute identifies approximately $193 billion in annual business activity influenced by sexual-orientation data. Businesses use this information across advertising, audience measurement, consumer research, content development, market segmentation, and other commercial functions. While published estimates specifically quantifying the economic value of gender-identity data are more limited, businesses likewise use information concerning gender identity in market research, workforce analysis, consumer engagement, and strategic planning. The existence of a robust private-sector market for LGBTQ+-related demographic data demonstrates their economic value.
The issue is therefore not whether businesses use sexual-orientation and gender-identity information. They do. The relevant question is whether the data that remain available after adoption of the proposed rule will provide comparable reliability and utility. Existing surveys can produce valuable national-level estimates, but their usefulness declines as businesses seek information about specific local markets, industries, or demographic subgroups.
By categorically prohibiting the collection of sexual-orientation and gender-identity information through population enumeration, the proposed rule would eliminate the possibility of a decennial population benchmark without demonstrating that existing alternatives can provide equivalent accuracy, precision, or economic value. Before foreclosing that option, the Bureau should establish that any loss of potentially valuable economic information is justified by measurable gains in burden reduction, confidentiality
protection, or census accuracy.
Existing Alternatives Are Not Necessarily Comparable
Federal surveys and commercial datasets provide important information and should continue to do so. However, businesses rarely make decisions based solely on national averages. They need data that help them understand individual communities, regional markets, workforce demographics, and consumer behavior. As survey populations are divided into smaller geographic areas and more detailed demographic categories, sample sizes shrink and estimates become less reliable. While existing surveys may generate useful national estimates, they are often less effective for understanding smaller populations or local market conditions.
A census-scale benchmark would provide a substantially larger population base and could improve the quality of demographic estimates used throughout the public and private sectors. Such information could strengthen market research, economic analysis, and commercial demographic products that businesses rely upon every day.
Importantly, many commercial demographic products are not independent substitutes for federal population data. They are built using survey responses, population controls, federal datasets, and statistical modeling. The quality of those products depends on the quality of the underlying population information available to them.
Questions That Should Be Addressed Before Finalizing the Rule
Because the proposed regulation would permanently foreclose the collection of sexual-orientation and gender-identity information through population enumeration, we respectfully request that the Census Bureau addresses the following questions before finalizing the rule:
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Whether existing alternatives provide comparable precision and utility: To what extent can current federal surveys and commercial datasets reliably measure sexual orientation and gender identity across geographic areas and demographic subgroups?
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What Census Bureau testing has shown: What conclusions has the Bureau reached regarding response quality, respondent burden, confidentiality protections, proxy reporting, and the feasibility of collecting sexual-orientation and gender-identity information?
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What value a population benchmark would provide: How are federal population data used to support commercial, academic, and governmental demographic estimates, and what would be lost by permanently excluding sexual-orientation and gender-identity information from future census enumeration?
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What information could be responsibly published: What demographic and geographic detail could potentially be released while maintaining robust confidentiality protections?
Conclusion
Information regarding sexual orientation and gender identity helps businesses understand customers, workers, entrepreneurs, and communities. These data have practical economic value and support informed decision-making throughout the public and private sectors. The proposed rule would permanently eliminate the possibility of establishing a decennial population benchmark for sexual orientation and gender identity while relying on alternative sources whose comparability has not been demonstrated. Before adopting a categorical restriction, the Census Bureau should establish that existing alternatives can provide information of comparable quality and utility and that any loss of economic, demographic, and analytical information is justified by clear and measurable benefits. Thank you for your consideration of our views and for your continued commitment to producing accurate, reliable, and useful demographic information for the nation.
Sincerely,
National LGBTQ+ & Allied Chamber of Commerce (NGLCC) Colorado LGBTQ Chamber of Commerce
Connecticut Gay & Lesbian Chamber Equality Chamber of Metro DC
Gay & Lesbian Chamber of Commerce Nevada Golden Gate Business Association
Greater Houston LGBTQ+ Chamber of Commerce Greater Phoenix Equality Chamber of Commerce Indy/Indiana Rainbow Chamber of Commerce LGBT Chamber of Commerce Illinois
Los Angeles LGBTQ Chamber of Commerce
Miami Dade LGBTQ+ and Allied Chamber of Commerce Mid-America LGBT Chamber of Commerce
New Mexico Out and Allied Business Alliance nglccNY
North Texas LGBTQ Chamber of Commerce Oregon Pride in Business
Plexus LGBT & Allied Chamber of Commerce Professionals With Pride
San Antonio LGBTQ+ Chamber of Commerce St. Louis LGBTQ Chamber of Commerce Tampa Bay LGBT Chamber
Tennessee Pride Chamber The Pride Chamber
Utah LGBTQ+ Chamber of Commerce
Wisconsin LGBT Chamber of Commerce