Public Comments
Comment Regarding Proposed Changes to Federal Racial and Ethnic Data Collection Standards
On April 25, 2023, the Center filed a public comment in response to the Office of Management and Budget’s (OMB) proposals for updating its race and ethnicity statistical standards (Docket No. 2023-0001). Racial and ethnic data collection can uncover racial inequities, and thereby reveal the racist policies and practices that cause those inequities. To better understand and track racism, the categories used for racial and ethnic data collection must closely approximate racialized experiences. This Comment provides insights based on our research and engagement with scholars and advocates regarding improvements to the federal standards for collecting and reporting racial and ethnic data. Specifically, the Comment supports moving to a single question format for collecting racial and ethnic data (Section I); adding a “Middle Eastern or North African” category (Section II); requiring further disaggregation of data (Section III); amending the terminology used in the current standards (Section IV); and conducting additional research to further improve the categories for the purpose of tracking and addressing racism (Section V). While these changes will not result in a perfect model for data collection, they are steps in the right direction to track and mitigate racism.
Response to White House Request for Information: Equitable Data Engagement and Accountability
On October 3, 2022, the Center filed a public comment in response to the White House Office of Science and Technology Policy’s Request for Information regarding “how Federal agencies can better support collaboration with other levels of government, civil society, and the research community around the production and use of equitable data.” (Docket No. 2022-19007) The Center provided recommendations with the aim of improving the quality and availability of racial and ethnic demographic data, so that researchers, advocates, policymakers, and the public can better assess whether government programs and policies promote racial equity or inequity. Specifically, our submission encourages the establishment of Chief Data Officers at multiple levels of government, the creation of a regular Intergovernmental Council of Chief Data Officers from within the government, and a process for continuously improving and standardizing racial and ethnic categories used in equitable data collection.
Comment in Support of Proposed Rulemaking: Collection of Self-Identified Ethnicity and Race Information for Federal Advisory Committee Nominees
On May 9, 2022, the Center filed a public comment in response to a proposed act of rulemaking by the Environmental Protection Agency (EPA) (Docket No. 2022-04403). The EPA proposal would require the collection of racial and ethnic information about federal advisory committee nominees. Our comment argues that the collection of this data is a necessary step in understanding racism and racialized outcomes. The comment also calls for public accessibility of this data to ensure effective oversight and transparency regarding the equitability of EPA’s policies and practices. Lastly, the comment recommends disaggregating the racial categories used for data collection to provide better information about racialized experiences.