Oppose H.R. 931, Making the American Community Survey Voluntary

Recipient: Chairman Gowdy and Congressman Davis

Honorable Trey Gowdy,
Chairman
Honorable Danny Davis,
Ranking Member
Subcommittee on Health Care,
District of Columbia,
  Census and National Archives
Committee on Oversight and
Government Reform
United States House of
Representatives
Washington, DC 20515

Dear Chairman Gowdy and
Congressman Davis:

On behalf of The Leadership
Conference on Civil and Human Rights, a coalition charged by its diverse
membership of more than 200 national organizations to promote and protect the
civil and human rights of all persons in the United States, we write to urge
you to oppose H.R. 931.  This bill
will make participation in the American Community Survey voluntary, except with
respect to certain basic questions, which would convert the U.S. Census
Bureau’s American Community Survey (ACS) from a mandatory to a voluntary
survey.  We believe that the
quality of estimates produced from a voluntary ACS would be severely jeopardized
for all segments of the population and all types of communities, and in
particular, the hard-to-count communities—people of color, low-income families,
people with disabilities, and English-language learners—that The Leadership
Conference represents.  We know
that your panel will review this issue at a hearing on March 6, 2012, and we
ask that the subcommittee include our letter in the official hearing record.

The importance of
high-quality, objective, and universal ACS data for the civil and human rights
community cannot be overstated.
For this reason, The Leadership Conference considers a fair and accurate
census and comprehensive ACS, which is a part of the decennial census, among
the most significant civil rights issues facing the country today.  Our wide-ranging efforts to promote
equality of representation and economic opportunity are guided significantly by
objective, inclusive data on America’s diverse communities and
populations.  For example, the
Voting Rights Act relies on ACS data to make determinations under section 203,
which requires jurisdictions with a large population of people who are not yet
English language proficient to offer language assistance during the electoral
process.  Both the government and
business sector rely on ACS data to help ensure appropriate employment opportunities
for racial minorities, people with disabilities, and veterans.

Public and private sector
decisionmakers also rely heavily on ACS data.  The federal government alone allocates more than $450
billion annually in program funds to state and local governments based in whole
or in part on ACS data.^[1]  Equally important, businesses of all
sizes rely on ACS data every day to make vital decisions about where to locate
and expand what goods and services to offer, the scope of employee training
needed, and long term investment opportunities.  Nonprofit organizations use the ACS to guide services to
those most in need and to measure the success of their programs.

Making the ACS voluntary
would undermine the only source of reliable data to guide these decisions.  In 2003, Congress directed the Census
Bureau to explore the possibility of making the ACS voluntary.  In two reports^[2]
and several more recent analyses, the bureau concluded that mail response rates
to a voluntary ACS would drop “dramatically,” by more than 20 percentage
points.  Cooperation in
traditionally low mail response areas (which tend to equate with hard-to-count
communities, such as people of color, low income families, and rural
households) declined even further when ACS response was voluntary.  In addition, a significantly higher
percentage of traditionally easier-to-count populations, such as non-Hispanic
Whites, failed to respond during the mail and telephone phases of the ACS.  These findings suggest that the quality
of estimates produced from a voluntary ACS would be severely jeopardized for
all segments of the population and all types of communities.

A decline in mail response
rates would force the bureau to use more costly modes of data collection, such
as telephone and door-to-door visits, thereby increasing the cost of the survey
by thirty percent ($60 million at the time of the 2003 field test).  Without an increase in funding in an
amount necessary to overcome low initial response rates, the Census Bureau will
be left with insufficient response to produce reliable data for smaller (e.g.
rural communities; towns; urban neighborhoods) areas and population groups
(e.g. people with disabilities; veterans; immigrant groups).  The consequence would be greatly
diminished quality of ACS data. 

For these reasons, we urge
you to oppose H.R. 931.  Converting
the ACS to a voluntary survey would have serious adverse consequences that
could leave the nation in a precarious decision-making vacuum and hinder its
economic recovery and future growth. 
Thank you for considering our views and for including our comments in
the official hearing record.  If
you have any questions, please contact Leadership Conference Census Task Force
Co-Chairs Terry Ao Minnis, Asian American Justice Center, at 202-296-2300 x127;
Max Sevillia, NALEO Educational Fund at 202-546-2536 x15; or Corrine Yu,
Leadership Conference Managing Policy Director at 202-466-5670.

Sincerely,

Wade Henderson
President & CEO

Nancy Zirkin
Executive Vice President