Comment to Office of Management and Budget on 2020 Census Post-Enumeration Survey


CLC filed this comment in response to disturbing evidence that the U.S. Census Bureau might provide less transparency about the accuracy and fairness of the 2020 Census than it did for past censuses. In recent decades, the Bureau has used data from its post-enumeration survey to calculate and publish estimated undercounts and overcounts for the U.S., for each state, and for large cities and counties within states. But according to documents disclosed under the Freedom of Information Act, the Bureau might not publish these coverage estimates for counties and cities after the 2020 Census.

These sub-state coverage estimates are critically important. When different parts of the same state are undercounted at different rates, the disproportionately undercounted communities lose their fair share of state funding and representation in statewide politics. Without sub-state coverage estimates, these communities may not know that they have suffered these injuries, and therefore will have less opportunity to advocate for policies that level the playing field. Suppressing sub-state coverage estimates also limits the ability of census advocates to engage in get-out-the-count efforts targeting historically undercounted areas. The Census Bureau therefore should publish sub-state coverage estimates, and should make sure it collects sufficient data to do so.