The U.S. Department of Commerce has indicated that it plans to include a question about citizenship on the 2020 Census. The NCL and its member organizations are deeply concerned about the effects that the addition of this question may have on the accuracy of the Census, particularly with regard to refugee and immigrant populations, and therefore on the availability of federal resources for programs that serve those populations.
In response, the NCL has taken action in two ways.
1. Signing on to amicus briefs filed by the Leadership Conference on Civil and Human Rights in legal cases on the issue: New York v. Commerce, California v. Ross, and City of San Jose and Black Alliance for Just Immigration v. Ross. For more information, including the text of the briefs and lists of those signing on, see the press releases issued by the Leadership Conference:
2. Submitting a comment in response to the public comment invitation in the Federal Register
The text of the NCL’s comment is reproduced below. For more information and guidance on submitting a comment of your own, visit the website of The Census Project. Note that the deadline for submitting a comment is August 7.
NCL comment on 2020 Census, submitted 25 July 2018
Departmental Paperwork Clearance Officer
U.S. Department of Commerce
14th and Constitution Avenue NW
Washington, DC 20230
The National Coalition for Literacy (NCL) is submitting this response to the comment request on the 2020 Census posted by the Department of Commerce in the Federal Register on June 8, 2018.
The NCL is a national coalition of the leading national and regional organizations dedicated to advancing adult education, family literacy, and English language acquisition in the United States. We envision a society where all adults are able to fulfill their potential and achieve their goals through access to high quality adult education and literacy services provided by an integrated and well-developed system.
As educators, we strongly urge the Commerce Department to remove the citizenship question from the 2020 Census form. Including this question will undermine the quality and accuracy of the Census in every community, because households will be afraid to participate, as demonstrated by preliminary evidence from Census test administrators in Rhode Island. Many administrators reported that residents refused to provide personal information because of the decision to ask about citizenship status, despite the question not being part of that test.
Including the citizenship question is therefore likely to put the Census at risk of a significant undercount, especially among hard-to-reach population groups that are already fearful of answering government surveys, according to the Bureau’s own research. These groups include immigrants with legal status and naturalized U.S. citizens, as well as minorities and individuals with lower educational attainment.
We include the two references cited in footnotes 1 and 2 for the benefit of the Department of Commerce in reviewing these comments. We direct the Commerce Department to each of the items cited, and ask that they, along with the full text of these comments, be considered part of the formal administrative record on this proposed rule for purposes of the Administrative Procedures Act.
Throughout our work in the adult education field, we have seen the potential of education and literacy to improve individuals’ lives, break cycles of intergenerational poverty, and empower individuals to contribute actively to their communities. Adult education services—which rely on accurate Census data to apportion resources—provide the foundation for adult immigrants and refugees to learn English and become naturalized citizens, and for these and other adults with low levels of educational attainment to earn high school diplomas/equivalents, prepare for postsecondary education, support their children’s educational and developmental success, and lift their families out of poverty.
The U.S. adult education system provides these services with extremely limited resources; as a result, it is only able to provide services to a fraction of the millions who would benefit from them. The primary source of federal funding for adult education is through Title II of the Workforce Innovation and Opportunity Act. A Census undercount would likely result in a reduced and/or inequitable allocation of federal funds provided to states through WIOA. This is especially troubling because the communities most likely to be undercounted if the citizenship question is included—those with heavy concentrations of immigrant families—are among those most likely to benefit from adult education services. Therefore, the National Coalition for Literacy strongly urges the Commerce Department to reverse its decision to include the citizenship question on the 2020 Census.
 U.S. Census Bureau. (2017). Respondent Confidentiality Concerns and Possible Effects on Response Rates and Data Quality for the 2020 Census. National Advisory Committee on Racial, Ethnic, and Other Populations Fall Meeting, November 2, 2017. https://www2.census.gov/cac/nac/meetings/2017-11/Meyers-NAC-Confidentiality-Presentation.pdf
 U.S. Census Bureau. (2017). Strategic framework for messaging in the American Community Survey mailing materials. https://www.census.gov/content/dam/Census/library/working-papers/2017/acs/2017_Oliver_01.pdf.