Letter to Census Bureau Director Robert Santos on Civil Rights Priorities

Uncategorized 01.31,22

View a PDF of this letter here.

January 5, 2022

The Honorable Robert Santos
U.S. Census Bureau
Office of the Director
4600 Silver Hill Road
Washington, DC 20233

Dear Director Santos:

On behalf of The Leadership Conference on Civil and Human Rights, a coalition charged by its diverse membership of more than 230 national organizations to promote and protect the rights of all persons in the United States, and our Census Task Force co-chairs, we write to congratulate you on your recent confirmation and swearing-in as director of the U.S. Census Bureau. We look forward to opportunities for continued stakeholder engagement regarding Census Bureau programs and are eager to continue our work to ensure usable data that reflect all of the population of the United States, including our most vulnerable communities. To that end, we would like to request a meeting with you and our Census Task Force as soon as possible to discuss our priorities as you commence your tenure at a critical moment in the history of the Census Bureau.

Our Census Task Force — made up of core national members of the civil rights community with expertise and strong interest in the Census Bureau’s various surveys, including the decennial census and the American Community Survey (ACS) — works to ensure that the Census Bureau collects and disseminates usable data that inform representation, civil rights enforcement, federal funding, and national and state policies. Our task force has identified and developed a comprehensive list of priority executive and legislative initiatives that represent a path forward for our country in advancing social and economic justice. The initiatives highlight the issues we believe the Census Bureau must address in order to ensure that our democracy rests on an inclusive foundation.

As you know, we led an unprecedented mobilization of our communities for the 2020 Census, seeking to achieve a fair and accurate outcome. Now that the counting is done, we wish to ensure that the fruits of our labor are reflected in the data, available for use, and capable of being assessed and evaluated in a transparent way. In particular, we urge the Census Bureau to:

  • Work with the Office of Management and Budget (OMB) to finalize the revision of the OMB Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity, including any updates to the standards reflecting research on the 2020 Census experience.
  • Work with OMB to develop and issue a statistical policy directive on sexual orientation and gender identity standards for federal statistics and administrative reporting.
  • Issue detailed assessments and evaluations of 2020 Census operations in a timely way, including the Group Quarters operations and NRFU, along with the identification of areas of improvement for the 2030 Census.
  • Implement a one-time mechanism to correct undercounts and other miscounts in the enumeration of Group Quarters and college students living in private, off-campus housing during the 2020 count.
  • With stakeholder input, design and implement strategies to remedy the overall undercount in 2020 Census data that will be used through 2031.
  • Actively engage with stakeholders regarding the potential expanded use of administrative records in future decennial censuses and other data collection programs, including the ACS, to ensure that research and testing focus on identifying and mitigating adverse effects on accurate and detailed enumeration or reliable measurement of historically undercounted communities that are also disproportionately absent in administrative records.
  • Release data, including from the Demographic and Housing Characteristics File and Detailed Demographic and Housing Characteristic File, and quality metrics related to the 2020 Census and undercount and overcount measures at lower geographic levels than is currently being provided or contemplated.
  • Seek the robust feedback of stakeholders prior to making any future decisions about the application of disclosure avoidance systems, especially with regards to ACS data. Additionally, conduct and release an assessment on the impacts of the application of differential privacy on 2020 Census data products and ensure that the planning for the use of disclosure avoidance systems for the 2030 Census commences earlier in the decennial census cycle than it did for the 2020 Census.

We look forward to the opportunity to work with you on issues of such importance to our country and democracy. We would like to host you at a special Census Task Force meeting on Tuesday, January 18, at 2 p.m. ET, or such other time as may suit your schedule. If you have any questions about the issues raised in this letter, please feel free to contact Census Task Force Co-Chairs Arturo Vargas, chief executive officer of NALEO Educational Fund, at [email protected]; Terry Ao Minnis, senior director of census and voting programs at Asian Americans Advancing Justice | AAJC, at [email protected]; or Meeta Anand, senior program director of census and data equity at The Leadership Conference, at [email protected].


Wade Henderson
Interim President and CEO
The Leadership Conference

Jesselyn McCurdy
Executive Vice President of Government Affairs
The Leadership Conference

Terry Ao Minnis
Senior Director, Census and Voting Programs
Asian Americans Advancing Justice | AAJC

Arturo Vargas
Chief Executive Officer
NALEO Educational Fund