Comment to OMB on Census Bureau Collection of Citizenship Information

CLC filed this comment opposing the Census Bureau’s attempt to collect state administrative records, such as Department of Motor Vehicles data, for the purpose of producing data on citizen voting-age population (CVAP). President Trump has suggested that by producing statistics on the CVAP of each census block in the United States, the Census Bureau will enable states to draw voting districts that deny representation to non-U.S. citizens and minors. However, CLC argues that even if this type of redistricting were acceptable in the abstract (which it is not), it could not be accomplished using the data the Census Bureau plans to produce. The Bureau’s CVAP estimates will be too unreliable for redistricting, in part because state administrative records on citizenship are notoriously outdated and riddled with errors. Moreover, the Bureau’s collection of state citizenship records puts the 2020 Census at risk by stoking fear of the Bureau among non-U.S. citizens and their communities.