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July 18, 2018

Ms. Jennifer Jessup

Departmental Paperwork Clearance Officer
Department of Commerce
Room 6616
14​th​ and Constitution Avenue, NW
Washington, DC 20230

RE: Comments on Proposed Information Collection, 2020 Census, Docket No.


Dear Ms. Jessup,

As representatives of Asian Americans for Equality (AAFE), a 44-year-old community

development organization in New York City, we are submitting our comments regarding
the proposed citizenship question on the 2020 U.S. Census form. We strongly urge the
Department of Commerce to remove this question, which will undermine the accuracy of
the Census, harm communities nationwide and weaken our democratic government.

Since its founding in 1974, AAFE has stood up for the rights of all people, advocating for
equal access to employment, housing and government services. For many years, our
organization has dedicated substantial time and resources to boosting engagement in
the U.S. Census within the communities we serve. AAFE has worked hand-in-hand with
the U.S. Census Bureau in “hard to count” communities in which mail-in response rates
are well below average. In 2010, we were proud to partner with the bureau, facilitating
greater access in neighborhoods where language and cultural barriers traditionally
hampered full participation in the Census. We hope to continue our productive
partnership again in 2020.
We firmly believe that an accurate and objective Census, providing detailed information
about the American public, is vitally important. It determines elected representation at all
levels of government. It also influences public funding levels for communities across the
country, drives business decisions and shapes our national and local priorities. The U.S.
Census Bureau is a widely admired institution, free of partisan politics. In our
increasingly divided nation, maintaining the integrity and independence of the Census
has never been more important.

In a statement released in March​, the Commerce Department ​said Secretary Wilbur

Ross concluded that adding the citizenship question was necessary to, “provide
complete and accurate census block level data,” allowing the government to accurately
measure the portion of the population eligible to vote. As leaders of an organization
deeply rooted in communities at risk of being undercounted, we can say unequivocally
that this decision will have the opposite effect -- stifling full participation in the Census.

In 2010, we went door-to-door with Census takers, and experienced first-hand the
reluctance of many residents to participate. Inclusion of the citizenship question will
undoubtedly heighten suspicions among many foreign born, low-income and
educationally disadvantaged households. AAFE works in immigrant communities every
day. Our staff members conduct English language and civics classes for more than 100
individuals annually. Each year, our Department of Justice-certified counselors help
2,500 clients prepare for U.S. citizenship. Our staff members routinely hear from
community members fearful and mistrustful of the federal government. Even without the
citizenship question, these growing concerns will pose new challenges for Census
takers in 2020.

Given the current tensions in our country, pledges from federal officials to protect
personal privacy will mean very little in many immigrant neighborhoods. ​The Census
Bureau’s own research​ found that asking questions about citizenship caused an
“unprecedented groundswell in confidentiality and data-sharing concerns among
immigrants or those who live with immigrants.”

The Asian population nationwide is growing faster than any ethnic group. At the same
time, one in five Asians live in hard to count Census tracts. New York City boasts the
largest Asian community of any American city (at more than one-million), yet Asian
representation in city, state and federal government continues to lag. Taking into
account the rapid population growth in our communities and persistent challenges in
gaining equitable representation, obtaining a fair and accurate count in the 2020
Census is all the more important.
For the reasons detailed in this statement, we implore the Commerce Department to
reverse its decision. Removing the citizenship question is critical to guaranteeing a fair
and accurate Census. It will go a long way toward fulfilling the federal government’s
responsibility, mandated by the U.S. Constitution, to count every living person. It’s the
right thing to do do for our communities, our government and our country.

Respectfully submitted,

Jennifer Sun and Thomas Yu

Co-Executive Directors
Asian Americans for Equality

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