The Leadership Conference on Civil and Human Rights

The Nation's Premier Civil and Human Rights Coalition

The Leadership Conference on Civil and Human Rights  & The Leadership Conference Education Fund
The Nation's Premier Civil and Human Rights Coalition

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

Advocacy Letter - 03/05/12

Source: The Leadership Conference on Civil and Human Rights
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.


Wade Henderson
President & CEO

Nancy Zirkin
Executive Vice President

[1] Reamer, Andrew, "Surveying for Dollars: The Role of the American Community Survey in the Geographic Distribution of Federal Funds," The Brookings Institution, July 2010 (http://www.brookings.edu/~/media/Files/rc/reports/2010/0726_acs_reamer/0726_acs_reamer.pdf).

[2] "Meeting 21st Century Data Needs - Implementing the American Community Survey, Report 3: Testing the Use of Voluntary Methods" (Dec. 2003) (http://www.census.gov/acs/www/Downloads/library/2003/2003_Griffin_01.pdf) and an update, "Report 11: Testing Voluntary Methods -- Additional Results" (Dec. 2004) (http://www.census.gov/acs/www/Downloads/library/2004/2004_Griffin_02.pdf).

Our Members