Canal Alliance’s Public Comment on 2020 Census Information Collection

Below is the Public Comment on Proposed Information Collection on the 2020 Census that was submitted by Canal Alliance via Regulations.gov on July 13, 2018.

We encourage all community members to educate themselves on the proposals and their impact on our communities and make your own voice heard before the August 7th deadline.

Edited with additional ways to add your voice to the opposition:

• Sign the ACLU Petition: Census Citizenship Question is Unconstitutional
• Submit your comment through Fair Immigration Reform Movement: #SaveTheCensus Petition

July 13, 2018
Ms. Jennifer Jessup Departmental Paperwork Clearance Officer Department of Commerce Room 6616 14th and Constitution Avenue, NW Washington, DC 20230

RE: Comments on Proposed Information Collection on 2020 Census, Docket No. USBC-2018-0005

Dear Ms. Jessup,

On behalf of Canal Alliance, we write to offer comments on the 2020 Census proposed information collection. We urge the Department of Commerce to remove the citizenship question from the 2020 Census form, as it will jeopardize the accuracy of the census in all communities—an outcome that the nation will have to live with for the next 10 years.

We believe a full, fair, and accurate census, and the collection of useful, objective data about our nation’s people, housing, economy, and communities, is vitally important. Not only is a nationwide census required by the Constitution, it is integral to our democracy, ensuring that district lines and political power are fairly drawn and allocated. The federal government uses census-derived data to direct at least $800 billion annually in federal assistance to states, localities, and families. The data also guide important community decisions affecting schools, housing, health care services, business investment, and much more.

Simply put, a fair and accurate census is essential for all basic functions of our society. That is why the 2020 Census should not include a question on citizenship that the weight of scientific evidence indicates will undermine a successful count of our nation’s people.

Marin County is among the wealthiest counties in the State of California, yet it is also home to some of the largest inequity. In 2017, the Canal Alliance Board of Directors, leadership and staff reflected on the glaring gaps in well-being and access to opportunity in the county. The Canal Alliance team envisioned our home as a more equitable place to live, work and raise our families. Building on Canal Alliance’s 35-year history of strong community partnerships and deep program learnings, we adopted a theory of change to break the generational cycle of poverty for immigrant families in Marin County. In order to achieve a higher level of impact for our clients, Canal Alliance is committed to a holistic approach that enables clients to achieve economic stability. Our primary strategy is to help clients access education and legal services, both of which have been shown to improve outcomes related to employment and income, and combined, have the greatest impact on improving economic outcomes for immigrants.

At the same time, we recognize that our clients face many challenges and barriers to accessing education and legal services. Not only do our clients struggle with poverty, but the experience of immigration itself is a health issue, as immigration is inseparable from trauma. Many of our clients have immigrated because of violence experienced in their home countries. This trauma is compounded by the stress and trauma of the immigration experience itself, as well as that related to the experience of trying to assimilate in a foreign country. With the current political climate, and frequent changes to immigration policies and enforcement, immigrants are now also living in a constant state of uncertainty and fear.

Canal Alliance is the leading service provider and community advocate for Marin County’s extremely low-income immigrant community. Each year, the organization collaborates with over 60 agencies and engages more than 500 volunteers to serve over 4,000 individuals and families. The agency is located in and primarily serves immigrants residing in the Canal neighborhood of San Rafael, which is a geographically isolated, densely populated area with over 12,000 residents in two square miles. The average annual income for a family of four residing in this neighborhood is under $35,000. Most clients come from remote areas of Guatemala, El Salvador and Mexico, and have less than an elementary school education. While Spanish is the primary language for most, some speak native languages and are preliterate in Spanish.

The community we serve is among certain hard-to-count populations and communities that have historically been prone to undercounting, inaccuracies and under-reporting in census data, making them a vulnerable and invisible population. Based on the 2010 Census data, approximately 7% of Marin County’s current population, or 19,310 people, live in hard-to-count neighborhoods, which include the Canal neighborhood. We believe there are three factors that will exacerbate the hard to count nature of our community:

• Housing
• Technology
• Citizenship question

Housing situations in the Canal represent the first factor that can have an impact on the census. In order to afford a two-bedroom rental unit in Marin County, families would need an annual income of $110,544. As mentioned earlier, in the Canal neighborhood of San Rafael, families earn an average of less than $35,000 per year. This discrepancy and the lack of affordable housing has caused overcrowding, rising rents, evictions, and poor living conditions. In fact, 51% of rented units and 14% of owner-occupied housing units experience overcrowding in the Canal.

Such unconventional housing is a major cause of census undercount. Examples include multiple families in a single unit and multiple in-law unit variations. Research indicates that one-third of the total undercount of low-income minority and immigrant families occurs as a result of their households being left out of the Census Bureau’s Master Address File. For the first time, the Census Bureau will be using In-office Address Canvassing for the 2020 Census. The use of electronic sources for the majority of the validation and updating of Master Address File (MAF)/ Topologically Integrated Geographic Encoding and Referencing system (TIGER) would lead to an undercount, thus perpetuating an existing issue of not being able to identify multiple families living in a single unit or in law residence.

Census self-response is also negatively impacted by a lack of access to a questionnaire. According to the Center for Urban Research Census Hard To Count Map Website, approximately 3,047 people (~0.4%) of the district’s current population live in tracts that did not receive a census questionnaire by mail in 2010. These areas did not have traditional addresses, had large numbers of seasonally vacant housing, or were otherwise rural or sparsely populated. According to the Census Bureau, the net undercount in these tracts was nearly 8% in the 2010 Census. Therefore, these areas will also be hard to count in 2020. Beyond these challenges, the additional use of internet technology to reduce manual effort would place more households at risk of being missed in the 2020 Census. According to the latest census American Community Survey in 2016, 8.9% of Marin County’s households had either no Internet subscriptions or dial up-only access.

Our third, and perhaps most critical concern, is that limited understanding regarding the citizenship question will increase the fear and anxiety within our community, making our clients reluctant to participate in the 2020 census. Since most federal government agencies base spending decisions on census data, the detrimental impact of undercounting will be far reaching and long-term. For example, the data from the 2010 Census showed that 98% of children in the local schools in Marin County qualify for free or reduced lunch. Without an accurate count, Marin County will not receive adequate funding to address childhood hunger.

Canal Alliance programs serve immigrants and their families. From our experience, immigrants often arrive with fear, trauma and distrust towards government institutions in their home countries. Recent stories of children being separated from their parents makes it very concerning for Canal residents to provide personal information about their families and acknowledge that they are not U.S. citizens and. We recognize that the citizenship question does not ask for the household’s legal status; however, the fear of what may happen after sharing personal information could discourage many of our clients from participating in the Census.

Immigrants and other hard to count populations live with trauma and fear every single day, we don’t want that reality to deprive them of the benefits of being counted. We believe that the addition of the citizen question will make it more difficult to meet the challenge of hard to count communities for a fair and accurate 2020 Census.

The harm from this decision (if it is not reversed) would be universal, with communities that are already at greater risk of being undercounted – including people of color, young children, and low-income rural and urban residents – suffering the most. An untested citizenship question will drive up costs as the Census Bureau struggles to develop new communications and outreach strategies with little time remaining, plan for an expanded field operation, and track down the millions of households that will be more reluctant to participate because of this controversial question. In sum, asking about citizenship status in a climate of fear and mistrust can only heighten suspicions, depress response rates, cost additional taxpayer money, and thwart an accurate, inclusive 2020 enumeration.

A full, fair, and accurate census is absolutely critical for our community. For the reasons discussed above, we strongly oppose asking about citizenship status in the 2020 Census and urge the Department of Commerce to remove the proposed citizenship question from the data collection forms.

Sincerely,

Canal Alliance

References: https://www.censushardtocountmaps2020.us/https://calbudgetcenter.org/resources/making-ends-meet-much-cost-support-family-california/