Ms. Jennifer Jessup
Departmental Paperwork Clearance Officer
Department of Commerce
14th and Constitution Avenue, NW
Washington, DC 20230

Submitted via regulations.gov

RE: Comments on Proposed Information Collection on 2020 Census

Dear Ms. Jessup,

The Economic Policy Institute (EPI) submits these comments in response to the June 8, 2018 notice in the Federal Register requesting comments on the 2020 Census proposed information collection. We urge the Department of Commerce to withdraw the citizenship question from the 2020 Census questionnaire, as it will significantly undermine efforts to achieve an accurate census.

EPI is a nonprofit, nonpartisan think tank created in 1986 to include the needs of low- and middle-income workers in economic policy discussions. EPI conducts research and analysis on the economic status of working America and assesses policies with respect to how well they further those goals. Our research and analysis are virtually always based on data—including census data—and as a result, the quality and accuracy of data is of the utmost importance to us. We agree with the Census Bureau’s own Scientific Advisory Committee (CSAC), a committee of appointed academics and other census experts, who strongly disagreed with the decision to add the citizenship question. Among other issues, they noted that the bureau normally tests a new question thoroughly for many years before adding it to a survey, but in this case added the citizenship question with no testing or research. Adding a last-minute, untested question is an outrageous departure from acceptable data collection techniques.

Further, recent decennial censuses have already resulted in net undercounts of many communities, including communities of great concern for our research—for example communities of color, and low-income and immigrant populations. Growing distrust of the government will almost surely make it even harder to achieve a fair and accurate count—particularly in hard-to-count communities. The Census Bureau’s own research in 2017 found unprecedented concerns among immigrants, and those living with immigrants, about responding to census takers’ questions, due to fear that the information might be used against them or their loved ones. An untested citizenship question will drive up costs as the Census Bureau struggles to develop new communications and outreach strategies with little time remaining, plan for an expanded field operation, and track down the millions of households that will be more reluctant to participate because of this controversial question.

We are particularly concerned that the Commerce Department is adding an untested citizenship question at a time when years of congressional underfunding have already undermined the Census Bureau’s ability to conduct an accurate census. Funding constraints already led to the cancellation of testing in rural areas and Puerto Rico in 2017 and the elimination of two of three “dress rehearsal” sites in 2018. The lack of testing for key operations leaves the Census Bureau unusually unprepared to prevent and mitigate shortcomings in the implementation of the 2020 Census and the added burden of the citizenship question greatly exacerbates these concerns. But despite these worries—and Census Bureau staff warnings that adding the citizenship question would increase non-response rates for the 2020 Census, impair the accuracy of the data, and increase costs—the Commerce Secretary instructed the Census Bureau to add a citizenship question to the 2020 Census survey.

This action by the Commerce Secretary has united people across the political spectrum in deep concern that the quality and accuracy of census data will be jeopardized. Two former commerce secretaries—a Republican and a Democrat—oppose adding the question. Six former Census Bureau directors, appointed by different political parties, also oppose adding the question, along with mayors and other elected leaders from both political parties. And of course, data users and academics who rely on accurate, quality data for their research are strongly opposed to the last-minute addition.

Asking an untested question about citizenship status will depress response rates, cost additional taxpayer money, and thwart an accurate 2020 Census. In other words, the last-minute question profoundly jeopardizes our nation’s ability to meet its constitutional mandate to count every person. Given the enormity of what’s at stake, we request that the citizenship question from the 2020 Census be withdrawn. Thank you for your attention.

Sincerely,

Heidi Shierholz, Ph.D.
Economist and Director of Policy at the Economic Policy Institute in Washington, D.C.