NACo submits comments on 2030 Census Address Update Program

Key Takeaways

On April 20, 2026, NACo submitted formal comments to the U.S. Census Bureau on the proposed reinstatement of the Local Update of Census Addresses (LUCA) Operation for the 2030 Census. The Bureau had issued a Federal Register notice in February 2026 opening a 60-day public comment period on the program's design before submitting it to the Office of Management and Budget (OMB) for approval. 

See NACo’s Letter  

What is LUCA? 

LUCA is a voluntary program that gives tribal, state and local governments the opportunity to review the Census Bureau's residential address list for their jurisdictions and submit additions, deletions or corrections before the decennial census begins. Because census enumerators use the address list to locate and count households, an incomplete or inaccurate list leads directly to an incomplete count.  
For counties, the stakes are high -  census population data determines the allocation of hundreds of billions of dollars in federal formula funding each year for programs that counties administer including Medicaid, the Community Development Block Grant, Title I education funding, public housing, Head Start, highway formula distributions and broadband deployment, among many others. 

The 2030 LUCA program will run from May 2027 through September 2029 and includes several changes from the 2020 cycle, including a longer review window, new web-based tools and the elimination of all paper materials. 

What was included in NACo’s recommendations? 

NACo's comments focused on five areas: 

•      Recognize counties' role: Counties cover more land area and serve more diverse populations than any other general-purpose local government. They also directly operate many group quarters facilities, including county jails and nursing homes, that have historically been challenging to enumerate. NACo urged the Bureau to factor this into its program design and provide county-specific guidance on group quarters review. 
•    Provide real federal support for under-resourced governments: The 2030 LUCA is fully digital, with no paper-based alternative. The Bureau's current guidance for governments lacking technical capacity is simply to collaborate with larger governments. NACo urged the Bureau to go further by creating a dedicated technical assistance program, providing capacity-buildi ng resources and publishing clear plain-language guidance for governments with limited staff. 
•    Start outreach early: With the formal program not beginning until May 2027, there is a risk that many eligible governments will not begin preparing in time. NACo encouraged the Bureau to engage national, state and regional local governments and associations as partners in outreach planning well before the formal start date and to publish a readiness guide as soon as possible. 
•    Strengthen Title 13 confidentiality messaging: NACo urged the Bureau to clearly and publicly affirm that address information submitted through LUCA carries full Title 13 protections and cannot be shared with other federal agencies or used for any purpose beyond improving the census address list. 
•    Reconsider the burden hour estimates: The Bureau estimates an average burden of 13.5 hours for small governments, a figure NACo believes may substantially underestimate actual county burden, particularly for jurisdictions onboarding new digital tools for the first time. NACo requested county-specific estimates and an exploration of whether federal funding could help offset participation costs. 

Why this matters now? 
NACo's comments also noted concern about the Census Bureau's recent decision to cancel four of the six planned 2026 census test sites, including planned tests of rural enumeration strategies. That decision means the Bureau will enter the 2030 Census without field-tested methodologies for many of the communities most at risk of being undercounted, making strong LUCA participation by local governments an even more important safeguard for an accurate count.