The Leadership Conference Comments on the Revisions to the American Community Survey
Dear Ms. Dumas:
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 civil and human rights of all persons in the United States, and the undersigned organizations, we appreciate this opportunity to provide comments in response to the Department of Commerce request for review and approval of changes to the U.S. Census Bureau’s American Community Survey (ACS), published in the Federal Register on March 10, 2023 (the “notice”). We urge the Census Bureau to pause its research into possible elimination of the ACS ancestry question, an effort that we believe is premature in the absence of any detailed race and ethnicity subgroup or national origin data from the 2020 Census as a point of comparison and in the midst of an in-depth review of OMB Statistical Policy Directive 15.
The Leadership Conference is the nation’s oldest, largest, and most diverse civil and human rights coalition and provides a powerful unified voice for the many constituencies we represent. Our coalition views an accurate and fair census — and the collection of useful, objective data about our nation’s people, housing, economy, and communities generally — to be among the most important civil rights issues of our day.
Our longstanding role as a Census Information Center has allowed us to lift up within our broad civil rights coalition the fundamental importance of comprehensive, high-quality data about our population, communities, and economy. We also have a long history of first-hand experience working in support of the decennial census and the ongoing ACS.
While we appreciate the importance of respecting respondents’ time when completing the ACS, we believe the Census Bureau must continue the collection of data needed to monitor and enforce anti-discrimination laws and ensure equity and fairness in government policies and programs — absent clear evidence that data of comparable quality, substance, and granularity are available through other sources. Consequently, we are deeply concerned about the proposal to eliminate the ACS ancestry question, and we urge the bureau to delay any decision on this topic until there is clear research and evidence to support such a change, as well as public engagement with stakeholders and data experts.
There are several reasons why we believe any decision to drop the ancestry question from the ACS is premature and deserves additional scrutiny and transparency.
1. The rationale for considering elimination of the ancestry question is not supported by any publicly available research. While the Census Bureau points to the collection of detailed subgroup or national origin data for the White and Black and African American categories in the ACS race question, we are not aware of any publicly released research findings comparing responses to the ancestry question with race question responses. That research is essential if stakeholders and data users are to evaluate the proposal to eliminate the ancestry question. It is possible, for example, that respondents view their “ancestry” — and the ancestry of their household members, including children — differently than they view their race or ethnicity subgroup or national origin. Furthermore, a thorough evaluation of the proposal should include a comparison of ancestry data with 2020 Census data on national origin or subgroup identities; that comparison cannot be done until the bureau releases the Detailed Demographic and Housing Characteristics files later this year and next year.
2. There is no publicly available information to evaluate the suggestion that data collected through the race question can meet the specific legal and programmatic needs underlying the justification for the ancestry question. All questions on the ACS must collect data needed to meet federal statutory, programmatic, or case law requirements. According to the Census Bureau, ancestry data are used to ensure that government programs and policies “fairly and equitably serve the needs of all groups” and to enforce anti-discrimination laws, regulations, and policies. There is no publicly available information to evaluate whether data collected in the race question would meet those same federal agency needs in a comprehensive, comparable way.
3. Possible revisions to the OMB standards for collecting and presenting data on race and ethnicity could affect the way people respond to a proposed combined question, thus making any decision on whether to eliminate the ancestry question premature. Numerous census stakeholders have been focused on the proposed revisions to OMB Directive 15 for many months, which included a Federal Register Notice calling for public comments in late January on proposals to revise the standards significantly. Publication of the proposal to consider eliminating the ancestry question during the same time period has made it difficult for stakeholders to fully evaluate what many view as a consequential change in ACS content
4. The absence of public briefings or discussion of the possible elimination of the ancestry question is not in keeping with the Census Bureau’s new focus on transparency and stakeholder consultation. We believe that the goal of transparency would be best furthered by providing further updates to stakeholders and a more robust opportunity for comment as the research progresses. Since the 1980s, at least, interest in data collected in the ancestry question (previously through the “long form” and now via the ACS) has been high. Members of Congress and a diverse group of stakeholders fought to maintain this question on the long form when the Census Bureau proposed eliminating it to reduce respondent burden before the 1990 Census. Prior to the 2010 Census, the bureau tested the possibility of including a version of this question, alone or as part of the race question, on the form sent to all households. Given past support for this question, we believe any effort to remove it from the ACS must include meaningful communication with the broad census stakeholder community, as well as multiple opportunities to learn more about the proposal, ask questions, and offer feedback. We note that the initial Federal Register Notice outlining proposed revisions to ACS content and data collection methods, published in September 2022, did not include any reference to the possibility of dropping the ancestry question.
Thank you again for the opportunity to provide feedback on the proposed changes to ACS content and methodology. We appreciate your consideration of our views. If you have any questions about these comments, please contact Meeta Anand, senior director of the census and data equity program at The Leadership Conference on Civil and Human Rights, at 202-466-1887 or [email protected].
Sincerely,
The Leadership Conference on Civil and Human Rights
Asian Americans Advancing Justice – AAJC
Association of Population Centers
The Center for Social Innovation
Coalition for Human Needs
Georgetown Center on Poverty & Inequality
MACS 2030 – Minnesotans for the ACS and 2030 Census
NALEO Educational Fund
National Urban League
Partnership for America’s Children
Population Association of America