1990 CENSUS AND HOUSING DATA FOR THE

ELDERLY: CAN WE COUNT ON IF

JUL

JOINT HEMte

BEFORE THE

SUBCOMMITTEE ON HOUSING AND CONSUMEK

INTERESTS

AND THE

SELECT COMMITTEE ON AGING

HOUSE OF REPEESENTATIVES

ONE HUNDREDTH CONGRESS

SECOND SESSION

FEBRUARY 24, 1988

Comm. Pub. No. 100-663

Printed for the use of the Select Committee on Aging

U.S. GOVERNMENT PRINTING OFFICE

83-794 |t WASHINGTON : 1988

For sale by the Superintendent of Documents. Congressional Sales Office

U.S. Government Printing Office, Washington, DC 20402
SELECT COMMITTEE ON AGING

EDWARD R. ROYBAL, California, Chairman

CLAUDE PEPPER, Florida

MARIO BIAGGI, New York

DON BONKER, Washington

THOMAS P. DOWNEY, New York

JAMES J. FLORIO, New Jersey

HAROLD E. FORD, Tennessee

WILLIAM J. HUGHES, New Jersey

MARILYN LLOYD, Tennessee

MARY ROSE OAKAR, Ohio

THOMAS A. LUKEN, Ohio

BEVERLY B. BYRON, Maryland

DAN MICA, Florida

HENRY A. WAXMAN, California

MIKE SYNAR, Oklahoma

BUTLER DERRICK, South Carolina

BRUCE F. VENTO, Minnesota

BARNEY FRANK, Massachusetts

TOM LANTOS, California

RON WYDEN, Oregon

GEO. W. CROCKETT, JR., Michigan

IKE SKELTON, Missouri

DENNIS M. HERTEL, Michigan

ROBERT A. BORSKI, Pennsylvania

RICK BOUCHER, Virginia

BEN ERDREICH, Alabama

BUDDY MACKAY, Florida

NORMAN SISISKY, Virginia

ROBERT E. WISE, JR., West Virginia

BILL RICHARDSON, New Mexico

HAROLD L. VOLKMER, Missouri

BART GORDON, Tennessee

THOMAS J. MANTON, New York

TOMMY F. ROBINSON, Arkansas

RICHARD H. STALLINGS, Idaho

JAMES McCLURE CLARKE, North Carolina

JOSEPH P. KENNEDY II, Massachusetts

LOUISE M. SLAUGHTER, New York

JAMES H. BILBRAY, Nevada

MATTHEW J. RINALDO, New Jersey,

Ranking Minority Member

JOHN PAUL HAMMERSCHMIDT, Arkansas

RALPH REGULA, Ohio

NORMAN D. SHUMWAY, California

OLYMPIA J. SNOWE, Maine

JAMES M. JEFFORDS, Vermont

THOMAS J. TAUKE, Iowa

GEORGE C. WORTLEY, New York

JIM COURTER, New Jersey

CLAUDINE SCHNEIDER, Rhode Island

THOMAS J. RIDGE, Pennsylvania

CHRISTOPHER H. SMITH, New Jersey

SHERWOOD L. BOEHLERT, New York

JIM SAXTON, New Jersey

HELEN DELICH BENTLEY, Maryland

JIM LIGHTFOOT, Iowa

HARRIS W. FAWELL, Illinois

JAN MEYERS, Kansas

BEN BLAZ, Guam

PATRICK L. SWINDALL, Georgia

PAUL B. HENRY, Michigan

BILL SCHUETTE, Michigan

FLOYD SPENCE, South Carolina

WILLIAM F. CLINGER, JR., Pennsylvania

CONSTANCE A. MORELLA, Maryland

PATRICIA F. SAIKI, Hawaii

MANUEL R. MIRANDA, PH.D., Staff Director

PAUL SCHLEGEL, Minority Staff Director

SUBCOMMITTEE ON HOUSING AND CONSUMER INTERESTS

DON BONKER,

MARILYN LLOYD, Tennessee

BEVERLY B. BYRON, Maryland

TOM LANTOS, California

RICK BOUCHER, Virginia

BILL RICHARDSON, New Mexico

HAROLD L. VOLKMER, Missouri

BART GORDON, Tennessee

JAMES H. BILBRAY, Nevada

EDWARD R. ROYBAL, California,

(Ex Officio)

Arkansas,

Washington, Chairman

JOHN PAUL HAMMERSCHMIIT

Ranking Minority Member

GEORGE C. WORTLEY, New York

THOMAS J. RIDGE, Pennsylvania

SHERWOOD L. BOEHLERT, New York

BILL SCHUETTE, Michigan

WILLIAM F. CLINGER, JR., Pennsylvania

PATRICIA F. SAIKI, Hawaii

MATTHEW J. RINALDO, New Jersey,

(Ex Officio)

WILUAM F. BENSON, Staff Director

PATRICIA C. LAWRENCE, Minority Staff Director

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^R-LfM^-'lT-
^

' A s^V CONTENTS

MEMBERS OPENING STATEMENTS

Page

Chairman Edward R. Roybal 1

Chairman Don Bonker 2

Louise M. Slaughter 5

Thomas J. Tauke 6

Constance A. Morella 7

Mervyn M. Dymally 7

CHRONOLOGICAL LIST OF WITNESSES

Joseph R. Wright, JR. Deputy Director, Office of Management and Budget 8

Arthur F. Young, former Chief, Housing Division, U.S. Census Bureau 20

Hon. Arthur J. Holland, Mayor, Trenton, NJ; and Vice President, U.S. Conference of Mayors 36

Margery Austin Turner, Senior Research Associate, The Urban Institute, on

behalf of the Housing Statistics Users Group 38

Patricia C. Becker, Planning Department, City of Detroit, MI 53

APPENDIX

A Appendix I. Exchange of letters between Wendy L. Gramm, Administrator for

^ Information and Regulatory Affairs, Office of Management and Budget, and

C^ Charles D. Jones, Associate Director for Decennial Census, Bureau of the

I Census, submitted for the record by Chairman Edward R. Roybal 75

, Appendix II. "The 1990 Census and Housing Data for the Elderly: Can We

V Count on It?" A briefing paper submitted by Chairman Edward R. Roybal.... 92

•Q Appendix III. "Census Questions and OMB's Review of the Census Bureau

1 Proposal; A Summary and Brief Analysis," a report prepared by the Congressional Research Service, Library of Congress, and submitted for the

record by Chairman Don Bonker 9°

Appendix IV. "The Office of Management and Budget's Changes to the 1990

Census: A Critical Commentary, submitted for the record by Patricia C.

Becker, Planning Department, City of Detroit •

120

Appendix V. Gwen Rubenstein, Senior Program Associate, OMB Watch,

Washington, DC, letter 130

(in)

1990 CENSUS AND HOUSING DATA FOR THE

ELDERLY: CAN WE COUNT ON IT?

WEDNESDAY, FEBRUARY 24, 1988

U.S. HOUSE OF REPRESENTATIVES,

SELECT COMMITTEE ON AGING, AND

SUBCOMMITTEE ON HOUSING AND CONSUMER INTERESTS,

OF THE SELECT COMMITTEE ON AGING,

Washington, DC.

The joint hearing was convened, pursuant to notice, at 9:30 a.m.,

in room 311, Cannon House Office Building, Hon. Edward R.

Roybal (Chairman of the Select Committee on Aging) and Hon. Don

Bonker (Chairman of the Subcommittee on Housing and Consumer

Interests) presiding.

Members present: Representatives Roybal, Bonker, Kennedy,

Stallings, Slaughter, Bilbray, Wortley, Smith, Saxton, Bentley,

Meyers, Schuette, and Morella.

Staff present: Manuel R. Miranda, staff director; Valerie Batza,

executive assistant; Brian Lutz, professional staff member; Diana

Jones, staff assistant; of the Select Committee on Aging. Bill

Benson, staff director; Brian Lindberg, legislative assistant; and

David Dean, staff assistant; of the Subcommittee on Housing and

Consumer Interests,

Chairman ROYBAL. Good morning. This morning, due to time

constraints of our first witness, we will dispense with the opening

statements, and they will be included in the record at this point

without any of us having to read them.

[The prepared statement of Chairman Roybal follows:]

PREPARED STATEMENT OP CHAIRMAN EDWARD R. ROYBAL

Good morning ladies and gentlemen. The purpose of today's joint hearing of the

Select Committee on Aging and the Subcommittee on Housing and Consumer Interests is to examine how proposed changes in the content and sampling methods of

the 1990 decennial census will affect the ability of public officials and the private

sector to effectively plan for the needs of older Americans.

In the fall of 1987, the Office of Management and Budget, citing its authority

under the Paperwork Reduction Act, rejected several components of the Census Bureau's proposed questionnaires and sampling methods for the dress rehearsal of the

1990 census. Scheduled to be tested during the spring of 1988, these questionnaires

are intended to be an operational dry run of the actual census to be taken in 1990.

Among the changes OMB proposed are to: one, eliminate three housing-related

energy questions; two, move virtually all of the housing questions from the short

form which goes to all households, to the long form which goes to a much smaller

sampling of households; and, three, reduce the number of households which receive

the long form from the Census Bureau proposal of 16 million households to 10 million.

I am greatly concerned that these changes are being imposed by OMB, despite

comprehensive analyses done by the Census Bureau and other experts in the public

(1)
2

and private sectors, which reveal that they strike at the very heart of the intent,

reliability and accuracy of the census data. Additionally, these changes ignore a 7

year process in which the Census Bureau put the census document and questionnaire through an extensive review and comment process. This process included the

participation of a great number and variety of experts throughout the Nation.

One of the serious problems which these experts have outlined concerns the proposed elimination of the question on annual utility costs. Without this question,

there is serious question whether Federal, State, or local officials will be able to calculate "gross rent," an item used extensively in housing cost analyses, including the

establishment of Fair Market Rents (FMRs). The FMR is used by the Department of

Housing and Urban Development to determine the amount of income which the elderly and other low income individuals must pay for subsidized housing.

Additonally, without this information being available in the 1990 census, comparisons with 1980 data would not be possible, ending long-term trend analyses from

previous censuses. Consequently, the proposed changes will prohibit the analysis of

the effects of housing policy during the Reagan administration.

These experts have also indicated that by reducing the sample size, the Census

Bureau and local planners will be unable to obtain detailed data on the income,

living arrangements and demographic characteristics of subpopulations of the elderly because sample sizes will be too small to yield statistically reliable results.

I am particularly concerned by proposals to reduce the sample sizes to as low as 1

in 20 in some urban areas. In my own district of Los Angeles, for example, overall

response rates to the decennial census have historically been low. Cutting back on

sample sizes will likely compound the problem of getting incomplete and inaccurate

data in major urban areas.

Despite all these serious changes and cuts, budget savings do not seem to be a

motivation for OMB's proposals. According to the Census Bureau, a cost analysis

has never been done on these proposals, and rough estimates indicate that any savings will likely be negligible in comparison to the total cost of the decennial census.

It is my understanding that the proposed budget for the census is the same now as

it was before OMB's changes. What is worse, the lack of detailed local housing data

could be extremely costly to local governments or the private sector. Many localities

would have to run much larger samples of census data to obtain statistically reliable results, or would be forced to implement their own local surveys. Few local governments have the resources to undertake such detailed surveys, and those surveys

which could be initiated would lack standardization of data.

In sum, preliminary information provided to my Aging Committee seems to reveal

little rationale for OMB's proposed changes. I am aware of no information which

indicates that the Federal Government will save money on this proposal, and there

appears to be very little support for the changes among organizations and professionals which utilize the census data. Even the expert quoted by OMB in today's

testimony before the Aging Committee•Professor Edward Deming•expressed surprise to my staff that he was being misinterpreted by OMB as justification for reducing the sample size in a decennial census. Although Professor Deming did write

the statement OMB attributes to him. Professor Deming told my staff, "any quotation that I made regarding smaller sample sizes does not apply to the census at all

as the census is engaged constantly in sample surveys as a model for the whole

world."

Every American, from State and local officials, to the private sector, to the most

vulnerable of our senior citizens, has a vital stake in the quality of information obtained through the 1990 census. It is the responsibility of the Congress to assure

that this information is complete and accurate. Based on the information and recommendations received at today's hearing, I intend to work closely with my colleagues in the House and as a member of the Appropriations Committee to ensure

that the census information is indeed reliable and responsive to the Nation's needs.

We are very fortunate to have with us today a very distinguished panel of experts

who can describe not only the nature of the proposed changes, but also their implications for the ability of local officials, administrators, and businesses to plan for

the needs of vulnerable groups such as the elderly, the poor, minorities, the disabled, and rural population. I look forward to today's testimony with great interest.

PREPARED STATEMENT OF CHAIRMAN DON BONKER

Good morning. I am pleased to convene this hearing of the Select Committee on

Aging and the Subcommittee on Housing and Consumer Interests with the distinguished Chairman of the Full Committee, Mr. Roybal. I commend my distinguished

colleague for his diligence concerning the 1990 census. This past fall Chairman
Roybal conducted a hearing which examined several census related issues. We have

worked together for the past 7 months to ensure that the 1990 decennial census

fully serves the public as the Nation's statistical base in the last decade of the century•and into the 21st century.

I want to also congratulate Mr. Dymally, the Chairman of the Subcommittee on

Census and Population. He has played an important role on the census issues. He

has been completely supportive on our efforts in behalf of the elderly and those who

wish to retain the integrity of the census. We will continue to work with our distinguished friend from California on this issue.

Today's hearing will examine the changes that the Office of Management and

Budget (OMB) has insisted upon for the 1990 decennial census. These changes include: deleting several housing and energy-related questions from the short form of

the census questionnaire which goes to each household; moving seven questions pertaining to housing from the short form to the long form•which serves as a sample

survey; and reducing the sample size used for the long form from 16 million to 10

million households.

We will hear from our witnesses about the implications of such changes in the

census. I am afraid, however, that these efforts to reduce necessary housing data

will only cover up the grim realities of the administration's failed housing policies.

Federal housing programs have been cut by more than 70 percent over the past 7

years and the dramatic increase in the number of homeless persons across our

Nation testifies to this. I suspect that the census data on housing is news that this

administration is not eager to have.

Mr. Chairman, I would like to comment on the impressive witnesses we have

before us today. To begin, we should acknowledge OMB's role in bringing this hearing about. We have tried for months to dissuade OMB from making this hearing

necessary by urging them to withdraw their proposed changes to the census and the

sampling process. Unfortunately they have not responded positively, which is why

we are now here. Representing OMB today is Mr. Joseph Wright, Jr., who is Deputy

Director of OMB. It is important to note that Mr. Wright is a former Deputy Secretary at the Census Bureau. I am certain, Mr. Wright, that your expertise with the

census will be important to today's hearing.

We are extremely privileged to have the Honorable Art Holland, Mayor of Trenton, New Jersey, as a witness today. Mayor Holland, in addition to his extensive

experience in running a major metropolitan area, is also the Vice President of the

U.S. Conference of Mayors, which is deeply interested in the data that will come out

of the 1990 census. I understand that he will be the next President of the Conference. Thank you for agreeing to testify. Mayor Holland.

Also testifying will be Arthur Young, former Chief of the U.S. Census Bureau's

Housing Division. Having retired in January of this year, he is clearly one of the

Nation's most informed individuals regarding the 1990 census and the justification

for the Census Bureau's original proposal.

Margery Austin Turner will present testimony this morning written by Raymond

Struyk. Both Ms. Turner and Mr. Struyk are research associates at the Urban Institute. Ms. Turner is representing the Housing Statistics Users Group which consists

of individuals committed to facilitating the flow of information between governmental producers of data on housing and interested users•such as State governments

and private businesses. I will submit for the record a list of this group's members,

but, needless to say, it is a diverse and very distinguished group represented here.

Patricia Becker of the city of Detroit planning department, is representing the

Council of Professional Associations on Federal statistics. She is an eminent expert

in census procedures and is also the author of an excellent report entitled The

Office of Management and Budget's Changes to the 1990 Census: A Critical Commentary," which will be placed in the hearing record with her testimony.

I will not take the time to discuss in great detail the history of the census and

what has happened during the past few months which has led to this hearing. I will,

however, highlight what I believe to be key issues that must be considered in this

controversy. For the hearing record, I would like to submit the Congressional Research Service document titled, "Census Questions and OMB's Review of the Census

Bureau Proposal; A Summary and Brief Analysis." This outstanding CRS product

was written by Daniel Melnick, a specialist in American National Government. Mr.

Roybal and I are most appreciative of Mr. Melnick for his objective counsel on this

complex issue. He is clearly one of the Nation's experts on this subject.

OMB's rejection of the Census Bureau's proposed census questionnaires and

sample size has been a concern of mine for some time. On August 24, 1987, I wrote

to James Miller III, Director of OMB, and requested that he withdraw the recommended changes and proceed with the census as developed by the Census Bureau
and submitted to Congress in March of 1987. However, on September 16, 1987, OMB,

citing its authority under the Paperwork Reduction Act, announced that it had rejected the Census Bureau's 1988 proposed dress rehearsal questionnaires. Subsequently, the bureau modified its questionnaires as OMB recommended and OMB accepted them.

The dress rehearsal questionnaires are an operational dry run of all features to be

used in the 1990 census. The dry run is scheduled to take place this spring. Historically, few adjustments to the actual census have been made after the dress rehearsal has taken place. This makes OMB's changes in the rehearsal questionnaires even

more significant and places a burden on Congress to act quickly to correct these

problems•which will affect the quality of data that is available until the next century, and perhaps well into it.

I am pleased to note that OMB in its written testimony for this hearing has

stated; "I would like to assure you that actions taken to date on our part are not

fixed in concrete, particularly those related to sample size. We will revisit these decisions without prejudice at the completion of the dress rehearsal and will keep the

committees informed of our progress." This is a significant step toward a reversal of

OMB's past positions, and, which, it is important to note, positions with which none

of the experts agree. Furthermore, OMB states: "First, let me assure you that no

final decision will be made regarding the 1990 census forms and sample design until

the results of the 1988 dress rehearsal have been studied and discussed by all parties that have a stake in the census." This is good news, and I hope that today's

hearing record will establish when the dress rehearsal and its evaluation will be

completed.

It is my understanding that the process used to develop the 1990 decennial census

as proposed by the Census Bureau was the most extensive, thorough, and professional effort to date. In fact, the Census Bureau held meetings and conferences in all

States with diverse groups and organizations and data users to determine the census

content. Despite this extensive 3-year process used by the census to develop the

questionnaires, OMB after several months of work with no consultation of any significance with experts in the field, intends to cut crucial housing data and data

which reveals important information about many groups including the elderly and

minorities. Art Young considers the data that will be collected in the 1990 decennial

census a quantitative benchmark in our Nation's history. I agree with his description, and I will do my best to stop an administration which has shown little regard

for programs that benefit older Americans, minorities, or the poor, from denying

those of us who do care the necessary data to make our case.

Let's set the record straight on who does benefit from the data that is gathered by

the census, and who would be negatively affected by the OMB proposals. The 1990

census will provide data that will be used by Federal agencies, State and local governments, utility companies, developers, health officials, builders, realtors, mortgage

bankers, and many more, including numerous organizations with interests in many

fields. It seems to me that the census data is beneficial to almost everyone.

For example, the General Accounting Office (GAO) reported that the housing data

are used extensively by local governments. Also, an American Planning Association

survey of its members showed widespread use of small area data even for such an

activity as locating adult day care centers. In fact, the block data, which would be

ruined under the OMB plan, was particularly meaningful to local planning.

I recently received an issue paper from the regional councils of the State of Washington regarding OMB's changes in the census plan. In addition to stating strong

opposition to the changes, they also note that regional councils and local governments long have been heavy users of decennial census data, especially at the

county, municipality, census tract, and block levels.

Suffice it to say, I believe that our witnesses will demonstrate that the information and data gathered by the census is good for vast numbers of Americans, and

that OMB's changes in the census plan are not. The experts the Federal Government has hired to do the census agree with this. Charles Jones, associate director

for the decennial census, said in a November 22, 1987 memorandum that, "the content and sample size reductions OMB has proposed will affect negatively the statistical reliability and general utility of census results during the decade of the 1990s."

Mr. Chairman, our witnesses will effectively describe many of the implications

that the OMB directives will have on the quantity and quality of data. I would like

to include in the hearing record the short staff analysis that was provided to Members. In addition, I would like to discuss several examples of the negative ramifications of OMB's changes in the census plan.

First, the OMB plan deletes three housing-related questions: one, what are the

yearly costs of utilities for fuel for this house or apartment?"; two, what kind of
heating equipment is used for heating water?" and; three, "which fuel is used for

heating water?"

Utility costs may not seem on the surface to be the most important piece of data

to us, but to the Department of Housing and Urban Development (HUD), for instance, it is very important. Without utility cost information, it is very difficult to

do accurate housing cost analyses. Gross rent (all rental housing related costs) is calculated in order to do comparisons between all types of rental arrangements and

with homeowners. Meeting our national housing goals depends on understanding

the cost of housing, yet, without gross rent this becomes exceedingly difficult.

HUD also uses gross data to develop its fair market rent (FMR) program for 2,700

areas in the United States. Without gross rent data, HUD would need to use statistical modeling techniques which have not proven effective. FMRs are important to

public housing authorities, older Americans and other low-income individuals, because they are used to calculate the amount of income which low-income residents

must pay for subsidized housing. Therefore, many of the housing programs that benefit low-income persons would be hurt by this OMB change.

Second, OMB has moved 7 of the 10 housing questions from the short form to the

long form. OMB justifies this action by stating it will reduce the burden on the

households that complete the short form. This would convert the entire housing section of the census into a sample survey producing estimates rather than producing

actual counts. Data will simply no longer be available on a city block by city block

basis or for small rural areas. •

An example of the harm this could cause for the elderly relates to moving the

questions asking if the household has a telephone to the long form. This question

assists local agencies concerned about the disabled, poor, and elderly's ability to

communicate during times of emergencies. We know that the lack of a telephone

could cause a life-threatening situation for a frail older or disabled person. Communities need to know how many people do not have phones and where they are located. This will not be possible under OMB's plan.

Third, OMB has recommended that the sampling size be reduced from 16 million

households (1 in 6) to 10 million households (1 in 9). This is extremely damaging

because it weakens the housing and the population census data. With this change,

the Census Bureau and local planners, administrators, and the private sector will be

unable to obtain data on income living arrangements and other demographic characteristics of subpopulations. These subpopulations include vulnerable subgroups

such as the elderly. Blacks, Hispanics and American Indians. The sample sizes will

be too small to field statistically reliable results.

At particular risk will be small area data and data on housing conditions of the

elderly. This information has been used extensively in the past. The elderly, who

constitute approximately one-sixth of the population, are an important subgroup to

this committee and its work. As today's testimony will show, dividing the elderly

into smaller subgroups by race or age (e.g., "old old") will not be feasible with a

sample of only 10 million households.

This is not acceptable to me or my distinguished colleague considering the many

important policy decisions that face us in the years ahead as a result of the greying

of our population. This hearing should help to set the record straight on these and

other related matters. I hope that OMB pays close attention to our concerns and the

insights of our expert witnesses.

In conclusion, Mr. Chairman, I again commend you for your work on improving

the 1990 census and the quality of data it should produce. I know that we will not

give up on these concerns•too much is at risk here. I hope that OMB joins with us

and our other witnesses in ensuring that we have the information necessary to meet

the many challenges ahead of us as we move into the 21st century.

PREPARED STATEMENT OF REPRESENTATIVE LOUISE M. SLAUGHTER

I would like to commend you, Mr. Chairman, for holding this important hearing

today. The Office of Management and Budget's proposed changes to the 1990 census

represent a serious threat to the Nation's elderly, minority, disabled, poor and rural

populations. These changes threaten the ability of policymakers to interpret and respond to the housing needs of these special populations.

I am concerned that OMB has proposed extensive changes to the 1990 census

without having fully examined the implications of these changes. OMB's recent rejection of the 1988 "dress rehearsal questionnaire" does not allow for adequate time

for the Census Bureau to review the proposed revisions. OMBs' proposed census

changes emerged mere months before the scheduled dry run which will effectively

lock them in unless Congress acts quickly.
6

These changes raise the question of the true political motivations behind OMB's

actions. By drastically reducing the ability to gather housing data from the 1990

census, policymakers will not be able to accurately gauge the effect of reductions in

housing assistance programs during the last 7 years. As a result of OMB's elimination of three utility related questions, comparisons regarding utility expenses will

also be impossible. OMB's proposed changes will seriously limit the ability of the

Federal Energy Assistance program to serve low income and elderly populations.

In addition, one question OMB is proposing to eliminate provides information to

the Department of Housing and Urban Development that is used to calculate "fair

market rents." HUD uses fair market rent to determine the amount which elderly

and low income individuals must pay for subsidized housing. Where does OMB propose this information will come from if not from the census?

The U.S. Census is the single most important source of data available to local.

State, and Federal policymakers, research organizations, planners, academics and

public and private interest groups. Because the census is such an important data

base, it is critical that it remain shielded from political manipulation.

PREPARED STATEMENT OF REPRESENTATIVE THOMAS J. TAUKE

I commend the chairman for convening this important hearing to continue to examine the 1990 census. As the U.S. Constitution requires, every 10 years we count

our country's population. The decennial census gathers essential data upon which

many Federal funds are distributed to individual States and localities. Based on

census data. State and local planners also target their efforts toward areas which

are in need of assistance. During the past year, several serious questions have been

raised about the content and distribution ratios of the various census forms. I am

hopeful that our witnesses will answer many of these concerns today.

The U.S. Census Bureau constructed the 1988 dress rehearsal census questionnaires in 1987. The initial short and long forms both contained important questions

regarding housing and energy. Part of the standard procedure for assembling the

dress rehearsal is a review by the Office of Management and Budget (OMB). In its

review, the OMB dramatically altered the short form and reduced the sampling size

for the long form from 17 to 10 million households. This reduction could compromise

the credibility and accuracy of the 1990 census. As a representative of a rural State,

I am particularly concerned by the potential lack of data on rural elderly.

According to the Census Bureau, a rural area is defined as an incorporated or unincorporated area with a population under 2,500. The 1980 census long form was

sent to 1 in 2 households in rural areas with populations under 2,500. The Census

Bureau intended to maintain this sample figure for the dress rehearsal and 1990

census. OMB revised the census proposal to sample sizes of 1 in 2 households for

population areas of under 1,000 and 1 in 6 for areas of 1,000 to 2,500, 1 in 10 households in population areas of 2,500 to 6,250 and 1 in 20 households in larger areas.

In previous census reports, the nonrural parts of the country were surveyed by

delineating "census tracks" or metropolitan and nonmetropolitan population areas

4,000 to 5,000 people. Under OMB revisions, urban statistical data could be inadequate and nonrepresentative of urban populations. It is my understanding, however, that the Census Bureau has the capability to extrapolate data based on a 20 percent ratio for the larger population areas. Conversely, a 20 percent sampling of

sparsely populated areas of the country could produce unreliable and inaccurate

data which would make county by county planning virtually impossible.

Additionally, the OMB eliminated several important energy questions regarding

home heating. Considering that the role of the Federal Government in funding

housing and energy programs have changed significantly during this decade, reliable data on the impact of these policy changes is essential. For example, people

who rent housing often do not pay for utility costs. Gross rent for renters may be

$400 per month, while a homeowner may spend $400 per month in mortgage and

$350 in utilities or a gross monthly housing expenditure of $750. This type of information should be available for Federal, State, and local governments.

In attempting to improve service delivery and program planning, State and local

governments must have reliable statistical data. This is particularly important for

rural America. The greying of America is already upon us in rural America. One of

the most vulnerable elderly groups are rural older women. Rural older women are

most often alone with little access to important services. As more and more young

people leave rural communities, the priorities of State and local governments will

have to shift toward increased public works, transportation and in-home services for

the rural elderly.
The 1990 census will likely document that the over age-65 group, and the over

age-85 group in particular, are the fastest growing age groups in my home State of

Iowa. State and local senior citizen programs will surely be jeopardized if unreliable

statistical data is not available for program planners. The 1988 dress rehearsal and

the 1990 census will provide us with critical data. Rather than limit the scope of the

specific information which we seek, the census should gather as much information

as possible. And I am hopeful that the problems between the OMB and the Census

Bureau can be resolved•to the satisfaction of the Congress•in the near future.

PREPARED STATEMENT OF REPRESENTATIVE CONSTANCE A. MORELLA

Mr. Chairman, thank you for calling this joint hearing to assess how proposed

changes in the content and sampling methods of the 1990 decennial census will

affect the ability of Federal, State, and local officials and the private sector to effectively plan for the housing needs of older Americans.

As the ranking Republican on the Subcommittee on the Census and Population, I

have been very concerned with the changes proposed by OMB to the 1990 census.

Last fall, I contacted Wendy Gramm, the then Administrator of the Office of Information and Regulatory Affairs, to urge that the original Census Bureau questionnaires and sampling methods be retained. I am very concerned that the proposed

changes will result in an incomplete census and will have a negative impact on a

number of population groups, such as the elderly, and those officials and planners

who must make policy and planning decisions at the Federal, State, and local levels

of government.

Mr. Chairman, I look forward to working with members of the Aging Committee,

as well as my colleagues on the Census Subcommittee to ensure that complete and

reliable information is obtained through the 1990 census.

PREPARED STATEMENT OF REPRESENTATIVE MERVYN M. DYMALLY

Mr. Chairman, thank you for allowing me to submit a statement at your committee hearing, "The 1990 Census and Housing Data for the Elderly; Can We Count on

It?"

As Chairman of the Subcommittee on Census and Population, I would like to take

this opportunity to share with the members of your committee the status of the

1990 census questionnaire and the role Congress can play in the final planning

stages of the decennial census.

Under its authorizing statute, the Bureau of Census is required to submit to Congress the final questionnaire for the decennial census by April 1, 1988, 2 years prior

to the actual census.

Congress will them have the opportunity to review the questionnaire and make

recommendations to the Census Bureau.

The Office of Management and Budget will also be looking at the questionnaire

under the auspices of the Paperwork Reduction Act. Once again, OMB will have the

opportunity to issue its opinion on the questionnaire, the process which produced

the decision that your committee is now considering.

Many of our colleagues. State and local governments, and census data users are

concerned with how the changes ordered by OMB for the 1988 dress rehearsal questionnaire will affect the 1990 census.

This is a legitimate fear because available analyses of the OMB ruling predict a

serious loss in the quality of the information collected under these circumstances.

For Federal programs which depend on census data for their effectiveness and efficiency, the loss would translate into a burden for policy-makers and beneficiaries,

alike.

Of all the subject areas, OMB, decision, for unknown reasons, seems to have targeted the collection of data used for housing programs. One would wonder if this is

not yet another attempt by the administration to abolish housing programs which

benefit minorities, the poor and the elderly.

Mr. Chairman, you will recall that we, along with some of our colleagues, sent a

letter to the Director of OMB urging reconsideration of his agency's decision on the

sample issue. Although OMB's response was somewhat vague, it did give me an indication that our point was well taken.

I commend you and your committee for holding this followup hearing. It is important to keep this issue on the top of our agenda because statistics gathered in the

upcoming census will help structure our Federal programs for the next decade.

My subcommittee will begin its hearings on the final questionnaire on April 14. It

is my intention to restore as much of the data targeted by OMB as possible.
8

If our recommendations are not accepted, it is likely that legislation will be offered to ensure that specific questions are included on the questionnaire. I hope you

and members of your panel will join me in the event that legislation is necessary.

I look forward to the testimony of the witnesses at your hearing. I intend to study

your hearing record in preparation for my subcommittee's review of the census

questionnaire.

Mr. Chairman, again, I thank you for the opportunity to submit a statement. I am

pleased to have been able to join you and your committee in the effort to make the

decennial census count for the elderly population of this country.

Chairman ROYBAL. I'm particularly pleased this morning that

Deputy Director of the Office of Management and Budget, Mr.

Joseph Wright, is here to testify before the committee. Given his

experience as President Nixon's Deputy Director of the Census, I'm

sure that he is familiar with the census issues and will be able to

answer our questions.

I understand that he is accompanied by Mr. MacRae, who is the

Acting Director of the Office of Information and Regulatory Affairs

at OMB. May I thank you for your appearance today. I understand

that your time is very limited and that you must leave soon. So

we'll proceed and ask the members of the panel to please come forward and take their respective seats.

Mr. Wright, will you please proceed in any manner that you may

desire.

STATEMENT OF JOSEPH R. WRIGHT, JR., DEPUTY DIRECTOR,

OFFICE OF MANAGEMENT AND BUDGET

Mr. WRIGHT. Thank you, Mr. Chairman. I have a prepared statement that I would like to submit for the record, with your permission; and I'd just like to make a few opening remarks, if I may.

First of all, we would like to describe how we see the role, as established by the Paperwork Reduction Act of 1980, of the Office of

Management and Budget in this entire area.

First, we have the responsibility to review all collections of information by the Federal Government to make sure that they have

practical utility and are not unnecessarily burdensome to the respondents. We also have to make sure that they do not duplicate

information available elsewhere.

Next we have to assure that the statistics produced and used by

the Federal Government are of the highest possible quality. That is

our intent as we carry out our responsibilities under the Paperwork Reduction Act, and that is exactly our intent in this case.

During the last summer and fall, we devoted a great deal of time

and effort to reviewing the plans for the dress rehearsal for the

1990 census, and I would like to emphasize, Mr. Chairman, that we

are talking about the dress rehearsal, which is a test prior to the

full census.

This is supposed to be taken next month. We reviewed and analyzed those proposals to make sure that they met the requirements

of the Paperwork Reduction Act, and we made certain recommendations to the Department of Commerce on the contents of the

short and the long forms and on the design and the size of the long

form sample. Again, our purpose was to improve the quality and

usefulness of the 1990 census data and the accuracy of the population count.
9

It is interesting, Mr. Chairman, over the last 10 years we've

found in general that the number of questions and the length of

the forms have remained about the same. There are a few changes,

for sure; but it has remained about the same, almost as if there's

been no progress made in the use of administrative records and our

ability to obtain census information from administrative sources.

So one of the concerns that we had was, are we unnecessarily duplicating information and, if so, is there a way to obtain that information from other sources? Are we pursuing something unnecessarily great expense not only to the taxpayers but to those people

who have to fill out the forms?

When we were working with the Census Bureau in the dress rehearsal review, our position was, let's try it out and have a dress

rehearsal as a test. Let's try to reduce the complexity, as if there

has been some progress made in the last 10 years•and I believe

there has•and if it doesn't work, let's go and make corrections for

the full census.

It was interesting, because we found this debate was not really

carried out amongst ourselves. This debate was primarily carried

out in the press, and in many cases in the Congress, before we

really had a chance to come and resolve many of the differences.

So I think this hearing is particularly useful, because the dress rehearsal will be next month. I think that all the questions, Mr.

Chairman, should get on the table. I think after the dress rehearsal

comes up with results, we will find whether or not the Office of

Management and Budget was correct in the fact that you can simplify some forms, and there has been some progress made over the

last 10 years, or that census was, or that•as probably will be the

case•the result will be somewhere in between.

Then what we would recommend from OMB is that you hold another hearing before we go into the final census to figure out what

is the best way to obtain this necessary information at the least

burden to the respondents. I think then we will have the best resolution of both worlds, and we will meet the requirements of the Paperwork Reduction Act.

I would like to assure the committee that no final decisions on

the 1990 census forms and sample design will be made until both

the Congress and the Executive Branch have had an opportunity to

review and carefully evaluate the results of that dress rehearsal.

We will revisit and evaluate these decisions, and we will be more

than happy to share all of the information that we get on this important subject with this committee and anybody else, because the

census is the largest single paperwork burden on the American

public, and I think we should take it seriously.

I am accompanied by Jim MacRae who is the Acting Administrator and Deputy Administrator for OMB's Office of Information and

Regulatory Affairs, who will be more than happy to answer any detailed questions you've got, Mr. Chairman. I've got a hearing over

on the Senate side on appropriations, but I think it is important to

come in and at least explain what our position is in the Director's

office in this particular area, and we welcome the fact that you are

holding these hearings and look forward to seeing you again after

the dress rehearsal.

[The prepared statement of Mr. Wright follows:]
10

STATEMENT OF

JOSEPH R. WRIGHT, JR.

DEPUTY DIRECTOR

OFFICE OF MANAGEMENT AND BUDGET

before the

HOUSE SELECT COMMITTEE ON AGING

and the

SUBCOMMITTEE ON HOUSING AND CONSUMER INTERESTS

FEBRUARY 24, 1988

Mr. Chairman and Members of the House Select Committee on

Aging and the Subcommittee on Housing and Consumer Interests: I

am pleased to be here to discuss the rationale for OMB's

recommendations on the forms and sample design for the 1990

census and explain why we believe it will result in an

improvement in the quality.and usefulness of the 1990 census

results.

First, let me assure you that no final decisions will be made

regarding the 1990 census forms and sample design until the

results of the 1988 dress rehearsal have been studied and

discussed by all parties that have a stake in the census. While

OMB agreed with the Department of Commerce that the dress

rehearsal should be conducted according to the plans intended for

the 1990 census, we also believe that Congress and the Executive

Branch should have an opportunity to evaluate the results of the

dress rehearsal and carefully analyze all other relevant

information before the 1990 census design is locked in final

form. When the results of the dress rehearsal become available

and we have reviewed them, we would welcome the opportunity to

discuss the issue of sample design again with your committees.

Let me briefly summarize the role the Office of Management

and Budget (OMB) has played in the development of the plans for

the 1990 census dress rehearsal.

Under the Paperwork Reduction Act of 1980, collections of

information by Federal agencies from 10 or more people must be

reviewed by OMB to assure that the information to be collected

and published will be as useful as possible to the government and

the public and that the burden on respondents is held to the

minimum practical level. OMB is also responsible under the

Paperwork Reduction Act for overseeing and establishing standards

for Federal statistical programs, to maintain and improve the

quality of government statistics.
11

On October 28, 1987, OMB completed a lengthy review of plans

for the 1990 decennial census dress rehearsal, a prototype of the

forms and sample design to be used in the census. The Census

Bureau submitted a first proposal for the dress rehearsal on

June 17, 1987. After careful analysis, consultations with

Federal agencies, and evaluation of almost one thousand comments

from members of the public, OMB concluded that the proposal did

not meet the practical utility and burden minimization

requirements set forth in the Paperwork Reduction Act. OMB

therefore disapproved the initial proposal on September 15, 1987.

In communicating the disapproval to the Department of commerce,

we recommended three changes in the proposal, which would allow

it to meet the requirements of the Paperwork Reduction Act. On

September 22, 1987, the Bureau of the Census submitted a revised

proposal for the dress rehearsal, which OMB approved on

October 28, 1987.

The revised plans for the dress rehearsal differ from the

initial plans in three respects:

1. Sevan of the tan housing questions initially proposed for the

short form will now be asked only on the long form • that

is, instead of sending these questions to all households in

the nation, they will be sent to a sample of households.

These are questions asking the number of rooms in one's home;

whether there are complete plumbing facilities; whether one's

house or apartment is part of a condominium; whether one's

house is on ten or more acres or has a business or medical

office on the property; whether there is a telephone; what

monthly rent is paid (for renters); and what is the estimated

value of the house or apartment (for owners).

The transfer of seven questions unrelated to the population

count will reduce the length and complexity of the short form

and eliminate questions that some groups of respondents have

indicated they regard as an invasion of privacy. We thus

believe it will encourage higher rates of mailback response

to the census short form. This rate dropped sharply from

1970 to 1980, and the Census Bureau had been anticipating

another sharp drop in 1990. A higher response rate will both

reduce the heavy cost of following up nonrespondents and

improve the likelihood of an accurate enumeration.

Asking the seven housing questions of a sample of households

rather than of all households will not have an adverse impact

on the accuracy of the data collected. In our opinion, there

is no gain in real accuracy from asking these questions of

the entire population, because the error that arises when

respondents either fail to answer the questions or provide

incorrect or inexact answers (nonsampling error) exceeds the

sampling error associated with any sample in the size range

contemplated for the 1990 census.

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12

3. A quaation asking for raapondanta• home telephone number,

initially proposed for the abort font, haa been eliminated

froa tha census questionnaires. Instead, respondents will be

asked on the back of the form for a telephone number where

they can be reached for followup purposes. In addition three

questions relating to fuel and utility uaa and ooata,

initially proposed for tha long form, have baan eliminated

froa tha census. These are questions asking about fuel used

to heat water; type of heating equipment; and annual bills

for electricity, gas, water, and oil or other fuels. To

enable the Bureau of the Census and the Department of Housing

and Urban Development to distinguish those rent payments that

Include utilities and heating fuels from those that do not,

the question on monthly rent has been expanded to gather this

Information.

The questions on energy and utility costs proposed for the

1990 census produce especially large reporting errors. When

questions such as those removed were asked in prior censuses,

the results were not published, because the errors were so

large that the estimates did not meet the Census Bureau's

publication standards.

We have had useful discussions with the Census Bureau and the

Departments of Energy and Housing and Urban Development (HUD)

concerning data on utilities necessary for HUD's Fair Market

Rent Program. We believe that Improved data can be collected

to replace the questions deleted from the long form and are

considering a strategy that would combine data from several

sources. For its part, we have asked the Census Bureau to

add simple questions necessary to distinguish rents that

Include utilities from those that do not.

The Energy Information Administration (EIA) has solved the

problem of inaccurate reporting of utility costs by

collecting actual billing data covering sample housing units

from utility companies. EIA also collects detailed

electricity costs for every community with a population over

2,500. Similar data from the American Housing Survey are

less accurate but can be used in conjunction with the EIA

data to improve estimates for small areas.

Information from the 1990 census, combined with the very

accurate measures of utility costs developed by the

Department of Energy, should permit the publication of

accurate, comprehensive utility cost estimates. Since these

costs area a very significant component of housing costs for

the elderly, data available after the 1990 census should be a

significant contribution to policy analysis concerning the

housing costs of senior citizens.

3. Tha design of tha long-form sample has baan raviaad. The

Initial sample design proposal was to sample one in six

households nationwide, a plan that would have resulted in
13

very small samples for rural and other sparsely populated

areas and very large samples for areas with high population

concentration, such as central cities. This plan would have

required a total sample of 16 million households. Under a

revised plan to be tested in the dress rehearsal, the Bureau

of the Census will vary the sampling rate among sampling

areas, so as to have approximately equal sample sizes and

sampling precision in all such areas. More than one in six

households • perhaps one in two • will be sampled in rural

areas and small government jurisdictions. In areas of very

heavy population concentration, fewer than one in six

households • perhaps one in twenty • will receive the long

form.

Large sample sizes do not always lead to accurate estimates

for subpopulations. The Initially proposed sample of 16

million households would have been the largest sample in U.S.

history, but the fixed rate design would have allocated this

sample so inefficiently that results might have been

Inadequate in less densely populated areas. In fact, the

sampling error in small rural areas would have risen to a

level five times the error of central city tracts. This

would have occurred because the fixed rate design would have

forced less densely populated areas to make do with smaller

sample sizes. The new variable rate design solves this

problem by ensuring comparable sample sizes, and therefore

comparable sampling errors, in all tracts throughout the

nation.

Answers to Committee Questions

In the letter inviting me to testify today, the Committee and

the Subcommittee asked specifically for the following

information:

Before finalizing the proposed changes in the census forms

and reductions in the sampling size of the long form, what

factors will be taken into consideration when determining their

impact on the ability of the Census Bureau, Federal Agencies and

local planners to crosstabulate housing data across smaller

subgroups of age, race, ethnicity, disability status, poverty

populations and other groups?

He believe that before making any final decisions on the

content and design of the decennial census, Congress and the

Executive Branch should have an opportunity to study the results

of the dress rehearsal. In particular we should examine unit and

item nonresponse rates, failed edit rates, and imputation rates

for the general population as well as for smaller subgroups of

age, race, ethnicity, disability status, and income level. Since

the logistics of any large population census are so complex, it

is also important to look into Census Bureau's ability during the

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14

dress rehearsal to find, hire, and train adequate numbers of

temporary employees and the ability of the Bureau to complete the

enumeration in a timely and effective manner.

It is important to realize that there is nothing to be gained

in being able to crosstabulate inaccurate data. One of OMB's

major concerns is that the quality of the data collected be high

enough to permit reliable analyses of smaller subgroups. The

primary factor OMB will consider when suggesting or finalizing

any changes is the impact of those changes on the accuracy of the

data first the accuracy of the population count and second the

accuracy of the demographic data derived from the short and long

forms.

We will also consider response burden, not only because it is

part of OMB's mandate under the Paperwork Reduction Act to assure

that it is held to the minimum practical level, but more

important, because it is a major factor affecting the quality of

response and the accuracy of census data.

What was the rationale for OMB's proposal to limit the sample

•is* of the long questionnaire form to 10 million bousing units?

Our primary objective was to ensure a quality enumeration by

keeping the census workload and respondent paperwork burden at a

manageable level. He are aware that some people feel that the

long form sample size should be increased in order to keep

sampling errors in urban areas at historical levels. Yet giving

millions more people longer forms does very little to increase

the quality of the census and it may have very adverse effects.

William Edward Deming, a world renowned statistician and pioneer

in the modern science of quality control, explains:

The overall usefulness and reliability of a survey may

actually be enhanced by cutting down on the size of sample

and using the money so saved to hire better interviewers and

to provide better training and supervision in the field, thus

trimming the biases of interviewing, response and nonresponse

more than enough to counterbalance the increased sampling

error.

Deming's message is simple • concentrate on quality, not

quantity. Concentrating on quality means studying all the

possible problems that occur in such a huge undertaking and not

focusing on the narrow issue of statistical sampling error.

We are particularly concerned that there will not be enough

competent employees available to complete the work generated by a

larger sample size. In 1980, the Census Bureau had tremendous

difficulties hiring enumerators. Two weeks before Census Day,

only 27.5 percent of the projected census takers needed had been

hired in Census's Dallas region, which includes Texas, Louisiana,

Mississippi, and Arkansas. Despite emergency pleas, hiring

-5-
15

targets were not reached around the country. Even after over

half the forms had been returned, some local offices in New

Jersey, New York, and Texas had only hired 25 percent of the

needed workers. If the Census Bureau is placed in a desperate

hiring situation by increasing the workload, it is likely to be

forced to accept employees that do not meet its minimum

standards. Errors caused or left uncorrected by a marginal or

understaffed workforce are a serious problem, especially since

the extent of the errors is never known. To avoid this problem,

the enormous decennial workload should be reduced in any way it

can without compromising the accuracy of the enumeration.

What is the impact of the proposed changes in content and

sample size on the reports which the Census Bureau Issues?

OMB does not determine what is included in Census Bureau

reports so we cannot answer this question definitively. However,

as far as we know, there should be no impact on the content of

the reports. Crucial data on age, race, sex, marital status, and

ethnicity • the most often-used classification variables for

tabulating socioeconomic data • will still be obtained from all

households. Questions on the number of rooms in the household,

complete plumbing facilities, whether the house or apartment is

part of a condominium and some others have been moved to the long

form but data will still be available for these items at the

tract level. Three questions relating to fuel and utility costs

and use have been eliminated but, as stated in my summary of our

revisions, much more accurate information can be obtained through

other means.

What is the basis for OMB'S assumption that "nonsampling

errors" will decrease with a reduction in sample size?

Nonsampling error should decrease with a reduction in sample

size because it is more easily controlled when the workload is

reduced. This argument is best explained in the Deming quote in

the answer to your second question.

One way to decrease nonsampling errors is to increase follow

up efforts. In 1980, 45 percent of the final census records or

persons, including both short and long form respondents, had one

or more missing data items. If responses can't be obtained for

missing items, the Census Bureau uses a procedure it calls

allocation to artificially create those items using information

from the records of other individuals. For some items, a

sizeable percentage of census data was artificially created. For

example the Bureau of the Census reported that on 8 percent of

personal records, "1975 residence" was artificially created.

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16

Unemployment experienced in 1979 was an artificially created data

item on 15.9 percent of all personal records. All or some

portion of household income was artificially created on 16.8

percent of all household records. These figures are troubling

because the extent of the statistical error introduced using the

allocation process is not Known.

Yet the issue of nonsampling error is not only one of sample

size. Certain types of nonsampling error are inherent in the

survey process and occur no matter what the sample size is. An

example may clarify the relationship between sampling and

nonsampling errors. Take, for instance, the question to

determine the value of a home. If we considered only sampling

error, we could design a sample that would permit us to make a

statistical statement such as, "We can estimate the average value

of homes within $2,000 with 95 percent confidence." But sampling

error does not give a true picture of the total error. How

accurately would the average person, call her Cindy Washington,

be able to estimate the value of her home? If Ms. Washington is

not thinking of selling her home at the time, she probably would

not be able to guess the market value within a $2,000 range. If

the neighborhood in which she lives is changing rapidly, the

value she reports would depend on when she filled out the form

and it would certainly change by the time the Census Bureau

finished tabulating its results.

Worse still, if she is like many other Americans and doesn't

want to provide this information to the government, her answer

would be artificially created by a Census Bureau computer. Under

these circumstances the estimate is unlikely to be accurate

within $2,000.

The Census Bureau recognizes these uncertainties in the way

the home value question is presented. If Cindy Washington's best

guess is $105,000 she would check a box on the census form marked

$100,000-125,000. When the Census Bureau receives the form, it

then estimates that the value of Ms. Washington's home is about

$112,500 plus or minus $12,500 (11 percent). This error of plus

or minus 11 percent is present whether the question is asked of

all households or a small sample. In this situation if we

doubled or even tripled the sampling error by reducing the sample

size it would not matter,'because the sampling error would be so

heavily outweighed by other sources of error.

In general, what are the implications of the current plans

for the census on the information that will be available into the

2lst century concerning older Americans?

Let me state emphatically that in no way will older Americans

be shortchanged by the revisions described earlier. On the

contrary, they will benefit, as will all citizens, from the

improvements made. We believe the revised plan will redress

disparities between the quality of the census data available for
17

urban and rural areas, lead to more accurate data on household

utility and fuel costs, reduce nonsampling error, and free

resources to allow for a more accurate population count.

Did OMB seek a legal opinion with respect to its ability to

•odify the Census Bureau's design concerning the collection of

housing data? In particular, on what legal basis did OMB

detenine that the statutory language of the Housing Act of 1949,

as amended, is insufficient to aeet the standard set forth in 44

D.s.c. 3504(a), which prohibits OMB froa exercising its paperwork

reduction authority if • collection of information is

specifically required by statute?

Questions concerning the scope and effect of the Paperwork

Reduction Act arose soon after the law was enacted and have been

thoroughly reviewed by OHB counsel. A mandate to collect data

does not imply that an agency is free to adopt an inefficient

design or to impose unnecessary reporting burden on respondents.

According to provisions the Congress placed in the Paperwork

Reduction Act, an agency's proposal to collect information must

be approved by OMB. To justify such approval, the sponsor agency

must balance the need for the Information and the practical

utility of its proposal against the burden on respondents and

cost involved. That is, even if the information is being

collected pursuant to a statutory requirements, OMB is still

obligated to ensure that the agency collects the information in

the least burdensome way practicable and that methods of

collection are consistent with govemmentwide information and

statistical policies.

The 1949 amendment to Title 13, which required a census of

housing, was subsequently amended several times. The requirement

for a "housing census" was completely eliminated in 1976 when the

Secretary of Commerce was directed to use the statistical method

known as "sampling" wherever feasible except "for the

determination of population for purposes of apportionment of

Representatives in Congress among the several States" (Section

195 of Title 13).

Mr. Chairman and Members of the House Select Committee on

Aging and the Subcommittee on Housing and Consumer Interests. I

would like to assure you that actions taken to date on our part

are not fixed in concrete, particularly those related to sample

size. We will revisit these decisions without prejudice at the

completion of the dress rehearsal and will keep the committees

informed of our progress.

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18

Chairman ROYBAL. Thank you, Mr. Wright. I have just two very

quick questions that I'd like to ask you personally. The first is, how

much money has OMB's cut saved from the 10 year cost of the decennial census? I think you made a point of the fact that there

would be savings by cutting back in the samples. Well, what are

the savings that you're talking about?

Mr. WRIGHT. My understanding, Mr. Chairman, and I would like

to have the opportunity to go and confirm this with our budget

people, is we are not talking about savings of Federal dollars here.

That is not the exercise that we're going through. We're talking

about savings of the paperwork burden on respondents. But I

would like to go back and just check that answer.

Chairman ROYBAL. We've heard from numerous groups and experts about the problems that you're talking about now, about the

cuts and so forth. Could you please tell us which organizations support your proposals? Do you actually have broad support, or is this

something that OMB is doing on their own?

Mr. WRIGHT. On the technical aspect, I would appreciate it if Mr.

MacRae could handle this, because he's been involved directly.

Chairman ROYBAL. All right. I really want to know whether this

is something that OMB has decided to do or whether you actually

have broad support and, if not, why are you proceeding the way

you are.

Mr. MACRAE. Mr. Chairman, if I could respond to that. Under

the Paperwork Reduction Act we are required to examine any information in a collection request, which the census is, to see that it

has practical utility, but there were other indications that there

was need to examine the 1990 census carefully.

The GAO has suggested that a shorter short form needed to be

tested. Internal census research has found that a number of groups

were offended by some of the questions, some of the housing questions that were on the short form and that we suggested be moved

to the long form.

So it was not just us carrying out our responsibility, as we must,

but it was also this indication from other parties, some concerns

about certain questions and concern also that the burden that's imposed by either the short or long form be kept to a minimum.

Chairman ROYBAL. Can you tell the committee what were the

groups that were offended by these questions?

Mr. MACRAE. Well, a number of minority groups have suggested

that the questions that are asked about the number of rooms in the

house could be used then to determine the number of inhabitants

of a particular abode, and may be used by someone to determine

that there was overcrowding and that, therefore, you might have to

reduce the number of persons in the house. So there's a sensitivity

on that question.

Chairman ROYBAL. Boy, that's really farfetched, isn't it?

Mr. MACRAE. Well, I'm not sure, Mr. Chairman. Those are personal questions•number of bathrooms, things like that. They are

obviously important to know. On the other hand, one doesn't want

to be in the situation where people won't answer because they are

offended by the question.

Chairman ROYBAL. NO, but shouldn't we know our status with

regard to housing in this country?
19

Mr. MACRAE. We have a number of other surveys, Mr. Chairman, besides the census where we do also gain information on the

status of housing, conducted by the Census Bureau and conducted

by other bodies. You are absolutely right; of course, we should

know, but what we don't want, I'm sure you agree, Mr. Chairman,

is the situation where people don't want to answer because they

may be offended by the way the question is phrased.

Chairman ROYBAL. I would like to pursue this, but I understand

you have a statement to make yet. Is that correct?

Mr. WRIGHT. No, Mr. Chairman. We submitted it for the record.

Chairman ROYBAL. All right. I am worried about the time that

you have to be leaving. As soon as that time does come, just feel

free to leave.

Mr. WRIGHT. OK. Mr. MacRae will stay for the entire hearing.

Ms. MORELLA. Before you leave, I am the ranking minority

member of the Census and Population Subcommittee, Post Office

and Civil Service. I have a packet here, about 61 letters that I have

received from organizations and individuals saying, please don't

take those questions out of the sample, but I haven't gotten one

that said take them out because of an invasion of privacy or because of overcount or whatever. Now maybe those people aren't

being vocal but, on the other hand, I can't help but be impressed

by these groups and individuals who say we need this data for a

number of other reasons and are really concerned if it is omitted.

I'm wondering, number one, under the Paperwork Reduction

Act, what does it say, just reduce as much as you can? Is there a

criteria that you look at that makes you say, these questions

should be taken out?

Second, how are you going to assess the validity of the sample on

the basis of the omission of those questions? Do you have a mindset

in advance that you think you can get this data from something

else? For instance, how can you get data on the number of telephones, et cetera?

Mr. MACRAE. The answer is that in some cases we can get the

data elsewhere. With regard to, for example, the estimates of heating costs, one of the things the Census Bureau has found is that

people often overestimate their heating costs. If you ask in April,

what are your annual heating costs, for example, for gas or electricity, many of them think of the last month, which might have

been a cold month.

By the way, this is Dorothy Telia, who is head of our Statistical

Office within OMB. I had asked her to join us here.

On the heating costs question, people then, therefore, take the

month of March or the month of February and multiply it by 12.

Census Bureau research has found that there's an overestimation.

Now the Energy Information Agency within the Department of

Energy also does, we think, a much better survey of heating costs.

They ask people, may we have permission to go to your utility company and get the actual billing, and people grant their permission.

Then, of course, you have actual hard data.

It's not that people try to be misleading, but it's just a matter

that collecting those data through that mechanism provides more

accurate data and gives us a better picture of heating costs across

the country.
20

You mentioned the fact that you have received no letters saying,

please reduce. We have a few letters in our file. One of the things

that concerns us when we carry out the Paperwork Act is that increasingly we are seeing a resistance on the part of the public to

complete long, detailed questionnaires. We saw it most recently in

the reaction to the very lengthy first W-4, and there were hollers

and screams all over the place. In fact, we were asked why OMB

let that first form go out.

Ms. MORELLA. That wasn't length. It was obfuscation.

Mr. MACRAE. Well, it was length and complexity.

So we think we have a responsibility. Our authorizing committees in both Senate and House have urged us to do our duty, that

sometimes the public is silent and that we have to make sure that

they have an opportunity to be heard; and where we think something is duplicative or where we think that we can reduce the

burden and get a better response as a result, we think that is what

we should do pursuant to the Paperwork Reduction Act.

Ms. MORELLA. My concern is that in trying to get the data that

we didn't ask, it ends up taking more time and energy to pull together from the different sources when you would be able to do it

from one questionnaire.

Incidentally, I think my utility companies overestimate when I'm

not there when they're reading.

Mr. MACRAE. Well, it's supposed to be accurate billing; but

you're right.

Chairman ROYBAL. The time of the gentlelady has expired. We

are going to proceed now in the regular order. We're going to ask

Mr. Young and the others to testify, and then come back, Mr.

MacRae, to you and to the young lady with you. Mr. Young, would

you please proceed in any manner which you may desire.

STATEMENT OF ARTHUR F. YOUNG, FORMER CHIEF, HOUSING

DIVISION, U.S. CENSUS BUREAU

Mr. YOUNG. Mr. Chairman, I appreciate this opportunity to testify, and I would like to submit my written testimony for the record

and then summarize my comments.

Chairman ROYBAL. AH right. Without objection, it will be the

order.

Mr. YOUNG. First, I'd just like to clarify what OMB did change.

They changed the 1988 dress rehearsal of the 1990 census, and the

dress rehearsal was to be a precursor for 1990, as much like it as

possible. So the changes are really changes in the 1990 census.

The plans the Census Bureau submitted had been developed

after 4 years of the most thorough and professional work I have

seen in my 35 years at the bureau. This proposal had less housing

content than 1980 and was the briefest housing census since 1950.

The changes made by OMB were to drop three questions entirely

from the housing census. They were: The cost of utilities; type of

heating equipment; and water heating fuel used.

To move seven questions from the 100 percent questionnaire

asked at every housing unit to the sample questionnaire. These

dealt with the presence of plumbing, the number of rooms, rent

paid, value for homeowners, condominium status, and telephones.
21

They also recommended that the sample size be cut from 17.7 million housing units to 10 million.

The rationale for these changes was not to save money, but to

improve data quality and to reduce respondent burden. I feel their

rationale is seriously flawed in terms of improving quality. In fact,

it will probably lower the quality of sample data, and that the

Census Bureau should comment on this. They are the experts and

have the experience.

The sample cut would result in about 7.5 million fewer long

forms being completed, which is not insignificant, at a savings of

roughly 30 minutes per questionnaire, but when viewed as a once

in a decade event and evaluated in terms of what completing these

forms means to the usefulness of the data, the 7.5 million long

form questionnaires appear to be very worthwhile to collect.

The primary purpose of the Decennial Census is to update our

population count for reapportionment and redistricting at the Federal, State and local levels, but the Nation has long recognized the

need for additional information and questions have been added to

the census since the early 1800s.

The OMB changes have little effect on data for big areas such as

the Nation as a whole. States or large metropolitan areas; but they

disregard the broad and pervasive uses of housing data at the local

level of cities and counties and the uses of sample and small area

data made by business and industries.

The data user will lose in two ways. First, small area data. The

housing data for blocks, both urban and rural, will be practically

eliminated. The housing data for census tracts or their rural

equivalents, areas of roughly 3,000 to 5,000 population, will have

crippling sampling errors. The local user's ability to tie data to the

ground will be lost or greatly blurred.

The second loss will be of small group data, data on the characteristics of subgroups of the population or of the housing stock,

such as the elderly, minorities, farm households, poverty households, one parent households, housing that lacks plumbing or is

crowded, low rent or low value housing, will either have substantial increases in sampling error or will not be available at the

block level.

The OMB cut will make the 1990 data on rental housing costs

different from all other censuses and surveys, and eliminate the

cost data for homeowners. Thus, meaningful comparisons between

1980 and 1990 housing costs will not be able to be made, and it will

be impossible to assess the impact of Reaganomics on the economics of American housing.

The OMB cuts will leave the Nation, after the 1990 census, with

a housing data base inadequate for sound decisionmaking at the

local level. As many housing activities have been moved from the

Federal to State and local governments, this may well delay and

frustrate the solution of housing problems in the 1990s.

The coming decade will find the Nation looking at questions on

housing affordability, homeownership, housing for the elderly, the

infirm, the poor, and in rural areas, energy shortages or high costs,

water and air pollution, daycare centers, housing discrimination,

growth or no growth policies, and probably many others, some of

which have not risen above the horizon.
22

These subjects warrant good, reliable data for small areas, so the

problems can be identified, discussed, analyzed and solutions

planned and evaluated. We are entering the new age of information. This is no time to dismember our socio-economic data base.

The situation we are in actually reminds me of a prank my children played on my wife. When they made their school lunches,

they carefully took the peanut butter from the center of the jar,

finally leaving nothing but a very thin layer on the inside surface.

Then, in one day, they emptied the last of the jar and complained

that she never had enough peanut butter in the house. The image

of that jar on the shelf is exactly what the housing census will be

for our local users. It will look like a full census, but it will be

nothing but a hollow shell.

If the Surgeon General had purview over the census, he should

put a warning on the cover of each sample report: "Caution: The

use of these data for small areas may be dangerous to your analysis."

Thank you.

[The prepared statement of Mr. Young follows:]
COMMENTS ON THE OFFICE OF MAMAGKMKMT

AMD BDDGETS CHANGES TO THE 1990 DECENNIAL CENSUS

TESTIMONY BEFORE A JOINT HEARING OF

THE HOUSE SELECT COMMITTEE ON AGING AND

THE SUBCOMMITTEE ON HOUSING AND CONSUMER INTERESTS

February 24, 1988

Prepared By

Arthur F. Young

Formerly - Chief Housing Division

U.S. Census Bureau

5911 John Adams Drive

Camp Springs, MD 20748

(301) 899-7987
24

The Office of Management and Budget directed the Bureau of the Census in the

fall of 1987 to make substantial changes in its plans for the 1988 dress rehearsal of the

1990 Decennial Census. As the dress rehearsal was to be as much like the 1990 Census as

possible, these directives are of great importance to all those who will use the 1990

data. In essence the Census Bureau was instructed to:

1. Drop three questions from the Census completely. These were;

A The cost of utilities

B Type of heating equipment

C Fuel used for water heating

2. Move seven questions from those planned to be asked at every housing unit to

those asked at a sample of housing units. TTiese were:

A Number of rooms

B Presence of complete plumbing facilities

C TTie screener question for rent and value

D Rent paid by renters and whether meals are included in rent

E Value of single family homes and condominiums

F Condominium status

G Presence of telephone in the unit

3. Cut the sample size to 10 million questionnaires, which is less than half the

sample that would have been enumerated if the 1980 sampling plan were to be

used in 1990 and a drop from the 17 to 18 million questionnaires from what the

Census Bureau had planned to collect.
25

Why was this done? It is hard to say. It was not done for budgetary reasons, as

the monetary savings are trivial in the perspective of the total decennial cost. OMB

indicates they believe these changes will improve response rates and data quality and

reduce respondent burden. Hie Census Bureau, in reply to OMB, has stated that based on

past experience improvements in response rates would be extremely small or nonexistent and that, in fact, data quality would be adversely affected. The reduction in

sample size would mean that about 7-1/2 million fewer "long form" questionnaires would

be filled at a savings to the public of about 30 minutes per questionnaire. TTiis reduction

occurs only once in ten years and would involve a small fraction of the Nation's

households. The savings in respondent burden seems small compared to the havoc it

would create in the Nation's statistical base, a base that will be used not only throughout

the 1990%, but as a quantitative benchmark in our Nation's history.

Before I discuss the impact of the OMB directives on the 1990 census results, it

should be pointed out that the Census Bureau began actively planning the content of the

1990 census in the spring of 1984. The Bureau held meetings and conferences in all

states and with a great variety of groups and data users including a Federal Agency

Council chaired by OMB to determine what questions should be asked. In my 35 years at

the Bureau which covered planning the 1960, 1970, 1980 and 1990 Censuses, the efforts

expended to determine the content of the 1990 Census were the most extensive,

thorough, and professional. This three-year program is described in a Census publication

entitled, "The Content Development Process for the 1990 Census of Population and

Housing" which clearly shows that the content determinations made by the Bureau's

experienced professionals were done carefully and reflect documented data needs.
26

As a result of this planning program some of the questions asked in the 1980

Housing Census were dropped from the 1990 plans. These were: 1) the number of

housing units at this address; 2) access to living quarters; 3) number of stories in the

structure and presence of elevator; and 4) fuel used for cooking.

Two questions were combined to shorten the questionnaire and inquiries were

added dealing with the unique out-of-pocket expenses of mobile home and condominium

occupants, and whether or not rent included meals. Before the original dress rehearsal

questionnaire was submitted to OMB for clearance, the Bureau's executive staff decided

to drop two additional questions: air conditioning and number of bathrooms. Thus, the

proposed 1990 Housing Census content was less than 1980 end, in fact, was the briefest

since 1950.

The Impact of the OMB Decisions

The directive to drop the question on utility costs will be a serious, if not fatal,

blow to the analysis of housing costs. Beginning with the first housing census in 1940, a

concept has been used call "gross rent." Gross rent is the sum of the rent paid to the

landlord (contract rent) plus what the tenant spends on utilities. Thus, "gross rent"

permits comparison between all types of rental arrangements. For instance, a tenant in

an apartment house may pay rent which includes all utilities (gas, electricity, and water)

and heat. In this case, contract rent equals gross rent. Another family may rent a single

family house and pays rent to the owner but also pays the electric, gas, and water bills.

Here, the gross rent would be the sum of the rent plus the cost of utilities. Gross rent

thus allows a true comparison of the out-of-pocket expenses paid for shelter by these two

families. There are, of course, many other rental arrangements where the tenant pays

for some but not till utilities, and in all instances "gross rent" permits meaningful

comparison and analysis across all rental units. In the 1980 Census this concept was
27

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extended to homeowner units where mortgage payments, taxes, insurance, and utility

costs were added to produce data on homeowner shelter costs, or the out-of-pocket

expenses for homeowners that could be compared to gross rent for renters. This 1980

Census innovation was applauded by data users and in the content planning process many

people urged that the homeowner shelter cost data be carried over to the 1990 Census.

Gross rent and homeowner shelter cost are also studied in relation to household

income. These data show what percent of a household's income is spent for shelter and

how this varies between income levels, between owners and renters, between the young

and the old, between different geographical areas and even between different

neighborhoods in the same city. These are the data that are needed to study our Nation's

growing housing affordability problem. Since 1970, housing costs have risen faster than

income, people are now spending a higher percentage of their income on shelter than

ever before.

These trends have accelerated in the SCs with the median percent of income spent

on rent reaching new highs and the high cost of owning a home reducing the percentage

of homeownership for younger Americans from 41.7% to 36.7%. Hie problem of housing

affordability, particularly for people with low, moderate, or fixed incomes, has become

critical in the 1980's. If we are to meet our national housing goals we will need to have

the best data possible on the cost of housing. By taking the utility cost data out of the

1990 Census we make comparisons with the 1980 data impossible, ending long-term trend

analysis from older censuses. The deletion of the utility cost question also leaves housing

program planners at the federal, state and local level with a fatally flawed data base on

housing costs that will not show the current problems or provide the facts needed to

arrive at much-needed solutions.
- 5 -

The gross rent data are also used by HUD in its Fair Market Rent program. The

removal of the utility cost question from the 1990 Census will force HUD to use

statistical modeling techniques or imputation to arrive at gross rent for the 2,700 fair

market rent areas in the U.S. I have no doubt that such a procedure is eventually

possible; however, it requires careful planning, extensive testing, and evaluation to

determine the proper data inputs and the accuracy of the results. I believe it is too late

in the decade to integrate a new and complex set of procedures into the basic decennial

census operations and that such a program would be quite costly. To produce gross rent

and homeowner shelter cost data on a timely basis for all geographic areas, large and

small, urban and rural at a minimal cost, the question on utility costs should be restored

to the 1990 Census questionnaire.

Hie question on heating equipment, which OMB eliminated, is also an important

question. Historically, it shows how the Nation's housing has progressed from hand-fed

coal and wood furnaces to automatic central heat and is now beginning to use heat pumps

and solar heat. But, more importantly, it shows local housing and health officials how

much of the housing stock uses antiquated or potentially dangerous heating equipment,

possibly posing a threat to the health and safety of the occupants. This is a problem in

rural America where stoves, fireplaces, and onvented heaters are used. The heating

equipment data, when compared to previous censuses, also shows how the nation has

reacted to the energy crisis by retrofitting furnaces or changing equipment and provides

the information at the local level which may be needed if the nation is faced with a

critical fuel shortage. Last, but not least, if statistical modeling is to be used to

estimate utility costs, the type of heating equipment is an important element in this

process.
The third question dropped by OMB, concerning water heating fuel, while not as

crucial as the first two, is also important. The original 1990 content as proposed by the

Housing Division at the Census Bureau contained questions on heating equipment and

heating fuels, water heating fuels, air conditioning, and the cost of utilities. This family

of questions was designed to provide basic data on residential energy consumption. Local

officials are concerned with energy consumption - particularly when demand exceeds

supply and there are brown outs or fuel shortages. However, the responsibility for having

an adequate supply, at moderate cost, of electricity, gas, fuel oil, and water, for a

growing and shifting population falls on the shoulders of local utility company officials.

Data on residential energy consuming equipment and energy costs that can be studied in

relation to the characteristics of the housing are essential to planning for the growth and

efficient use of our utility infrastructure. The integrated data collected in the Decennial

Census cannot be collected by local companies because of the cost and complexities.

Hie Census data are collected at one time and with uniform procedures in all 50 states.

This consistency, accuracy, and timeliness is essential for the accurate projections of

future utility needs. As can be seen, the "family" of energy questions has been badly

depleted. This will greatly reduce the usefulness of the Census for utility companies in

planning for the future and incomplete and inaccurate data may well increase utility

costs and create inconveniences.

More specifically, the water heating fuel question is important in warmer parts of

the country were more energy is used to heat water than to heat the home. It's also

useful for energy planning because many homes use a different source of energy to heat

water than the one used to heat the home and, finally, if utility costs are to be modeled

or imputed, the fuel used to heat water is an important variable.

83-79^ 0 -
30

OMB directed that seven questions listed previously be moved from the group

asked at every housing unit to those asked at a sample or small fraction of the nation's

housing units.

This directive creates a very basic change in housing data. The result of this

change is that in 1990 almost the entire housing census will no longer be a census but a

sample survey producing estimates rather than counts. This means that there will be no

more housing characteristics data, city block by city block or for very small rural areas.

The smallest geographic areas for publishing housing characteristics would be the Census

tracts or the rural equivalent, Block Numbering Areas (BNA), areas with 4,000 to 5,000

population or approximately 1,500 housing units. Cities and counties could no longer

assemble block housing characteristics data into areas that they needed for study or for

grant applications. This is like taking bricks away from a mason and saying you must now

build with stone blocks 2 feet by 4 feet by 8 feet.

It also means that TIGER, a computer mapping and geo-coding system created for

the 1990 Census, which identifies every city block and rural land area in the entire nation

coast to coast, and would have permitted for the first time the same fine grain

geographical identification for rural areas that has been available to urban areas for

decades - cannot be utilized to produce rural block housing characteristics data because

such data will not be collected. Thus, just when rural America was to obtain housing

statistical equity with urban America, the opportunity is lost.

TTie move of the questions on plumbing and on number of rooms to the sample will

greatly diminish the usefulness of these data to identify substandard housing. Tlie rooms

question is used in conjunction with the household population counts to produce data on

over-crowding. The plumbing question shows how many housing units lack complete
31

- 8 -

private plumbing facilities. These are the traditional indicators of sub-standard housing -

but sub-standard housing clusters, and there are greater differences in housing quality

between blocks than between census tracts.

Therefore, the resulting sample or census tract data on housing deficiencies will

be greatly weakened for four reasons:

1) They are not as geographically specific - because tracts contain many blocks (20

to 100); it will not be possible to accurately locate where the problem areas are.

2) The data will be subject to substantial sampling error. Thus, it will not be possible

to tell with confidence whether one tract has more deficiencies than another

except in extreme situations.

3) The differences in housing quality between the blocks within a tract will be

averaged out and appear as tract summaries and this, combined with sampling

error, will make it very difficult to determine differences in the level of housing

deficiencies between tracts.

4) The ability to measure housing quality for sub-groups within the tract such as the

elderly, minorities, one-parent households, renters, owners, or multi-unit

structures or the differences between sub-groups will be almost totally obscured

by a cloud of sampling error.

The same problems exist for rural areas and with the great dispersion of housing in

rural area the loss of 100% data on plumbing and crowding will be even more critical.

Moving the three questions on rent and value to the sample will have a disastrous

impact on local users of housing data and will also adversely affect all housing sample

tabulations. The 100% data on rent and value produced at the block level in 1980 were
used as micro level indicators of wealth and poverty. Tliey were the only socio-economic

data available at this geographic level and were published well ahead of the sample

income data. Moving rent and value to the sample will lose this geographic specificity

and delay their publication for at least a year.

Tiese items are also used to measure trends in property values and the effect of

environmental factors, social, economic and physical and other changes on rent and

value. Again - if these items are moved to the sample the ability to use them for subgroups of the population or housing stock is either lost or greatly diminished.

In 1980, the Census Bureau used the 100% rent and value data to improve the

quality of all housing sample data by a process known as "raking". Briefly, this process

made sure that the rent and value distributions in the sample tabulations agreed with the

100% distributions. As many housing characteristics are positively correlated with rent

or value, this improved all housing sample data. Moving rent and value to the sample in

1990 will eliminate this valuable technique and in comparison to 1980 increase the

sampling errors on the housing items.

The block by block rent and value data are used by other survey takers both in

private industry and in government. In designing their samples, they often use block data

and stratify their design by rent and value and, thus, are able to reduce sample sizes and

cost. Dropping the rent and value questions down to the sample will negate this use and

result in increased research costs and respondent burden throughout the decade of the

1990>s.

The question on condominium status was asked of all households in 1980 because

condominiums are relatively rare and tend to cluster. These two facts are still true and
33

- 10

make the data on condominium status subject to large sampling errors if it is collected in

the sample. Moreover, for those city officials and urban data users who wish to study the

shifts between 1980 and 1990 of rental property to condominium status and the

corresponding changes in housing costs, the sample information will give only the

broadest geographic picture and will be of little assistance in solving or studying local

problems.

The inquiry on telephones was included on the 100% questionnaire to meet the

need of those local agencies who are concerned with the elderly, the infirm, and the poor

and their ability to communicate in times of emergency. Lack of a telephone can be a

life-threatening situation for these people and information on how many households lack

phones and their location and characteristics are important, ITie Census Bureau needs

the telephone number of each household to conduct follow-up calls for missing or

contradictory replies and if the telephone question does not appear as a 100% data item

it will be asked on the back of every questionnaire for follow-up purposes and as a sample

question. It seems more efficient to ask it once as was proposed by the Census Bureau.

The third OMB directive is to reduce the sample to 10 million questionnaires. This

is probably the most damaging of all, for it weakens both the Population and Housing

Censuses.

In 1980 every sixth housing unit was in the sample except for places of 2,500

population or less, where every other housing unit was sampled. In 1970 a 1 out of 5

sample was used across the nation and in 1960 the sample was 1 out of 4. Thus, as time

has passed, the sample gets smaller and the sampling errors get larger. Data for the

Nation as a whole, entire states, or large metropolitan areas are quite accurate from

these samples, but problems arise with data quality when data for small areas or small
34

- n -

population groups are used. The housing data are more adversely affected than

population data because there are roughly one-third the number of housing units as there

are people and sampling error is primarily related to the number of cases in the sample -

not the size of the universe being sampled or the sampling fraction, that is, the fewer

cases in the sample, the higher the error. The OMB directive also indicated that a

varying sample fraction be used so that sampling errors would roughly be the same for

very small places (under 1000 population) and census tracts and BNAto of varying size.

What this plan boils down to is that the sampling error for most of the census tracts,

UNA'S, or smaller counties and communities for the housing sample items would be about

25% on a 10% characteristic. For example, if a Census report said about 10% of the

housing in a tract was overcrowded, that should be interpreted as: the chances are 2 out

of 3 that the true level of overcrowding is between 7.5% and 12.5%; and that there is one

chance in three that the true level of overcrowding is outside these limits. TTie Bureau

currently uses more stringent confidence limits and, if these were applied, the published

10% rate of overcrowding should be interpreted as the chances are 9 out of 10 that the

true level lies between 6.0% and 14.0% and that there is one chance in ten that the true

level is outside these limits. As most tracts have a rate of overcrowding that is within

the 6.0% to 14.0% range it becomes impossible to determine differences between tracts

or to rank them from most to least overcrowded. Similar problems occur with plumbing

data, but they are worse, because lacking plumbing is a 2% occurence and the relative

sample error on smaller groups is higher. Another problem arises with sample data on

infrequent items when the sample size is small and that is the "zero report". The

published data for many tracts on lacking plumbing may be zero but this may or may not

be true and confidence limits have to be applied to the zero report - thus, every zero

report may have to be interpreted as: there are 9 chances out of 10 the true value lies

between 0 and 1.7%. These data may be more confusing than useful and would be poor

indicators of the presence or absence of plumbing deficiencies.
35

12

The reduction in sample size to 10 million questionnaires would result in housing

tract, BNA and small place and county data with sampling errors so high that rational

decision making and planning at the local level would be almost impossible or done at

tremendous risk. The sample size should be restored to, at least, the 17.8 million cases

recommended by the Census Bureau.

The OMB directives for the 1990 census will do great damages to the small area

and small place data published by the Bureau and virtually eliminate the housing block

statistics program. Both the population and housing data will be hurt by the reduction in

sample size but the housing data will be wounded even more by the reduction in content

and the move of the 100% items to the sample. Data, both population and housing, for

small groups such as the elderly, minorities, poverty households, the disabled, and the

farm population, will be weakened and their usefullness reduced. For the people who

must resolve their problems, the local officials, the 1990 sample data will be a great

disappointment and even misleading.

The persons who will be hurt the most by these changes are in local government,

such as city and county planners, education administrators, public health officials,

transportation planners, housing authority administrators and officials who work with the

elderly, the disabled, and the poor. Private industry, the building materials

manufacturers, builders, realtors, appraisers, mortgage bankers and utility companies

will all suffer from the impact of a diminished data base that will make planning and

decisionmaking risky and difficult. In the long run, however, it will be the American

public that suffers since good statistics promote full employment, good business, and

healthy industries, producing better products and better services more quickly and at

lower costs. Good data help governments at all levels to recognize existing problems and

foresee future problems and plan efficient solutions. The 1990 census should be restored
36

Chairman ROYBAL. Congressman Smith, will you please proceed

and introduce your guest.

Mr. SMITH. Thank you, Mr. Chairman. First of all, I'd like to

commend you for your initiative in calling this hearing today to

discuss the 1990 census, proposed changes in the census data collection process and the potential impact of these changes on our elderly population.

As you are quite aware, Mr. Chairman, OMB has suggested that

the Census Bureau make several changes in both the questionnaire

and some sampling techniques used to collect the 1990 census data.

Today the Subcommittee on Housing and Consumer Interests and

the full committee is focusing its concern on the proposed changes

in the sampling size targeted to receive the long form questionnaire, and on the omission of certain important questions from the

short form.

Because the information collected by our national census is considered in countless public policy decisions which affect our entire

population, it is essential that we ensure that the information collected is both reliable and valid. Concerns have been raised regarding the effect OMB's proposal may have on the planning of housing

facilities for the aged. Clearly, the shifting or deletion of certain

key questions and inadequate sampling size may yield information

which underestimates the real housing needs of our Nation's elderlyToday, to address this important issue, I have the distinct honor,

the very special honor, to welcome and to introduce to you and to

members of the committee the Honorable Art Holland. Mr. Holland is the Mayor of New Jersey's capital city, the city of Trenton,

the largest municipality in the district that I represent, and Vice

President of the U.S. Conference of Mayors.

Mr. Holland's experience in the areas of public administration,

regional and urban planning and research analysis is quite extensive. Throughout his career, he has served on several boards and

commissions, including Chairman of the Subcommittee on Civil

Rights for the Conference of Mayors. He is currently the member

of the Advisory Council, National League of Cities and the Greater

Mercer Comprehensive Planning Council, just to name a few.

In the past he has served as Chairman of the Delaware Valley

Regional Planning Commission, the Cochairman of the Labor Management Relations Task Force, the National League of Cities and

President of the Mercer County League of Municipalities.

It is my great honor to welcome and to introduce to the committee Mayor Art Holland, Mayor of Trenton.

STATEMENT OF THE HONORABLE ARTHUR J. HOLLAND, MAYOR,

TRENTON, NJ; AND, VICE PRESIDENT, U.S. CONFERENCE OF

MAYORS

Mr. HOLLAND. Thank you. Congressman.

Chairman ROYBAL. Mayor Holland, please proceed in any

manner which you desire.

Mr. HOLLAND. Mr. Chairman and the committee, my name is Art

Holland. I am the Mayor of Trenton, New Jersey. I'm also Vice
37

President of the United States (Conference of Mayors, and I am appearing before this committee today representing both.

I appreciate the efforts of this committee in examining the impacts of proposed changes in the 1990 census questionnaire on the

elderly. The Decennial Census is no stranger to controversy. It

seems every 10 years there is much ado over the content of the upcoming census. This time, however, there is a large and ominous

difference.

The Office of Management and Budget is proposing fundamental

and far reaching changes in the coverage of the census by reducing

the sample size, on the one hand, and on the other reorienting the

content of the questionnaire.

The effect of these proposed changes on the accuracy and reliability of the data collected is being seriously questioned by those

who both use and trust this data. I would also note that, aside from

these changes, the Department of Commerce announced in October

last year that they would not adjust the 1990 census to correct for

the undercount of minorities which the Census Bureau acknowledges has, and will, occur.

The adjustment issue is a very serious one, and the United States

Conference of Mayors has taken a strong position in favor of utilizing the statistical techniques which currently exist to ensure the

most accurate count possible. Although adjustment is not an issue

before the subcommittee today, I feel it is an important one which

must not be neglected as we near decisions on the 1990 census.

To the matter at hand. The content and sample size issues could

have potentially debilitating impacts upon the cities of this Nation

as they strive to adequately plan for the future and allocate scarce

resources for the betterment of their residents and businesses.

For instance, the OMB proposal to reduce the sample size from

19 million in the 1980 census to 10 million in 1990 was made despite the recommendations of professional statisticians and without

specifically requesting input from data users outside.

It is clear, and one need not be a statistician to know, that limiting the sample size to 10 million will decrease the quality of data,

especially for numerically small populations such as American Indians, Hispanics and the elderly. For the Nation's cities, it is projected that using a sampling fraction of 1 in 20 will increase error

levels by at least 100 percent.

The potential loss in quality of block by block data is overwhelming. The city of Trenton worked hard with the very able United

States Bureau of the Census to provide an accurate and complete

1980 census. We cooperated with the complete count program and

the pre and post census local review programs to encourage and

ensure the accurate completion of the 100 count forms, and the

survey forms, which were mailed to 1 unit out of every 6.

The city employs this data to target its community development

block grant funds, its housing program funds, and its economic development monies to needy persons. The city depends on the detailed tabulations from the decennial census as its primary source

of information on the block level.

On the issue of content, OMB has recommended that most of the

housing questions on the short form be moved to the long form.

Also several long form questions on utilities are to be eliminated.
38

If these recommendations are followed, the loss of these 100

count questions will substantially reduce the amount of housing

data on a block basis, causing great harm to cities' ability to allocate their resources.

This type of housing information on a block level is used to analyze housing characteristics to prepare the housing element of the

master plan and to target neighborhood eligibility for Federal,

State and local assistance. This type of detailed information is used

to pinpoint areas in need of existing programs, and is crucial for

the development of future programs.

OMB asserts that much of this data is available from alternative

sources. However, alternate sources prepare estimates, not actual

counts, of data which cannot be standardized. The Census Bureau

is virtually the only source of data which is standardized nationally, easily accessible, widely known and consistently gathered with a

reputation for reliability.

Census data provide the baseline, the denominator, by which all

other sources, which are typically available at intervals more frequent than once every 10 years, can be used throughout the

decade.

In closing, the United States Conference of Mayors stands ready

to work with this committee and the administration to ensure that

the 1990 census data reflect the most accurate and reliable data

available. In our estimation, the proposals recommended by the

Office of Management and Budget must be seriously debated and

analyzed.

The importance of this data, not only from a city perspective but

also from a national perspective, cannot be overstated. I look forward to working with you, Mr. Chairman, and with members of

this committee in ensuring that all of our citizens not only count

but are counted.

Thank you.

Chairman ROYBAL. Thank you. Mayor. The Chair now recognizes

Ms. Turner, the Senior Research Associate for the Urban Institute,

to speak on behalf of the Housing Statistics Users Group.

Will you please proceed, Ms. Turner.

STATEMENT OF MARGERY AUSTIN TURNER, SENIOR RESEARCH

ASSOCIATE, THE URBAN INSTITUTE, ON BEHALF OF THE HOUSING STATISTICS USERS GROUP

Ms. TURNER. Thank you. Good morning, Mr. Chairman. I'm Margery Turner. I'm appearing here today in place of Raymond

Struyk, who is currently in Indonesia on a 3 month assignment.

Both Mr. Struyk and I are Senior Research Associates at The

Urban Institute where our work focuses on the analysis of housing

problems and housing policy issues. In particular, we are concerned

with the housing needs of the most vulnerable groups in society,

including elderly Americans, minority groups and those who are

poor.

We've submitted a written statement for the record, and I'm prepared to give a brief summary of it this morning.

Chairman ROYBAL. Without objection, it will be ordered.
39

Ms. TURNER. The changes that OMB has recommended will seriously undermine efforts to analyze housing problems and to plan

for housing absolutions. The deleterious effect of the proposed content and sampling changes will reinforce one another, thereby crippling housing analysis, particularly at the small area level. More

specifically, the seven critical housing questions will no longer be

available in the block statistics, so that analysis of most housing

problems and policy issues simply cannot be done at all at the

neighborhood level.

In addition, the proposed cut in the long form sampling rate

means that we can't be certain that housing data will continue to

be available even at the census track level. Confidentiality requirements will result in the suppression of data when the number of

observations gets too small; and this is likely to be an especially

severe problem when it comes to the housing circumstances of

small subgroups of the population such as the elderly and minorities.

Finally, the deletion of the three heating and utility questions

from the long form will make it impossible to measure total housing costs at any level, because utility costs are such an important

component of total housing spending.

Taken together, OMB's proposal seriously undermines the capability of analysts and planners to document housing conditions and

trends at the neighborhood level at a time when homelessness is on

the rise and housing is becoming unaffordable for an increasing

share of poor and working class Americans. Such a proposal is capricious and irresponsible.

I'd like to give a couple of concrete examples of the kind of planning for the housing needs of elderly Americans that would be

hampered by OMB's proposed changes.

The first example involves local home repair programs. Many

American cities operate home repair programs that help elderly

homeowners keep their housing in good condition. These programs

directly improve housing for the elderly who participate, and they

also enhance and stabilize overall neighborhood conditions. But to

make these programs work, it's often necessary to speak with the

homeowners individually to explain the opportunity that's being offered and to allay possible misgivings about participating in a government program.

To keep the cost of this kind of extensive outreach under control,

they need to be targeted to small geographic areas where the program is really needed most. The census block data has been extraordinarily useful to identifying these neighborhoods, since they

tell us where elderly people are living, how many are homeowners,

and what their range of house values is. In addition, the block data

give us a count of the units that lack complete plumbing, which is

a very useful shorthand measure of housing deficiencies.

Under the OMB proposal, only the presence of elderly persons

and the split between owners and renters would be available at the

block level. Local planners would not be able to figure out which

neighborhoods in their cities needed home repair assistance, and

they would not be able to target their outreach to elderly households in these neighborhoods.
40

The proposed OMB changes will also make it harder for the private sector to respond effectively to changing housing needs. In

recent years a number of new housing options such as small group

homes, continuing care communities and congregate housing facilities, have become popular with the elderly. Private providers are

actually beginning to respond to this demand and to provide these

kinds of housing options, but again detailed analysis of neighborhood conditions is critical for a private firm to select a site to build

such a facility.

Census block data report the number of elderly people in a

neighborhood, their range of house values and rent, and the presence of existing condominiums and congregate facilities. This information can help a private market analyst effectively choose potential locations for new housing solutions.

Again, under the OMB proposal information on house values and

rents would not be available at the block level, and the information

on condos and congregate housing which would be obtained only on

a sample basis might not be reliable even at the town and city

levels, because the incidence of this kind of housing is so low.

These are just two examples of the kind of small area analysis

performed regularly by local planners in both the public and the

private sectors.

It's been claimed that these types of analyses are done only infrequently, the implication being that the cost of including these housing questions in the short form can't be justified on the basis of a

few exotic examples. This claim is simply wrong.

An April 1987 GAO report which follows up on an earlier report

that was cited by OMB confirms that the small area data are used

frequently and extensively at the local level.

Let me turn now to the question of the utility questions that

OMB proposes to eliminate altogether from the census.

The data on utility costs are absolutely essential for measuring

the share of income being devoted to housing. Without these questions, it would be impossible to document the existence or severity

of housing affordability problems for the majority of cities and

towns in the Nation. And, obviously, no small area analysis of

housing cost problems would be possible.

The past decade has witnessed sharp increases in housing costs

and affordability problems, reaching crisis levels in some neighborhoods. Under these circumstances, when reliable information is

most needed as the basis for workable solutions, OMB's proposal is,

frankly, irresponsible.

In summary, I strongly oppose all OMB's proposed changes to

the 1990 census, because they will cripple public and private efforts

to understand and remedy the housing problems confronting America's most vulnerable groups, including the elderly, minorities, and

the poor. From the perspective of data users, OMB's action at this

late date in the planning for the 1990 census is clearly harmful to

the future of our national housing policy.

Thank you again for the opportunity to present my views.

Chairman ROYBAL. Thank you, Ms. Turner.

[The prepared statement of Mr. Struyk follows:]
41

Implications for Planning for the Elderly's Housing

of OMB's Proposals for the 1990 Census

by

Raymond J. Struyk

Testimony Presented by

Margery Austin Turner

Presented at the Joint Hearings of the

House Select Committee on Aging

and the

Subcommittee on Housing and Consumer Interests

February 24, 1988

Mr. Struyk is a Senior Research Associate at The Urban Institute. The

views presented herein are his own and not necessarily those of the

Institute or its sponsors.

Because Mr. Struyk is out of the country on assignment, Ms. Turner, also

a Senior Research Associate at the Urban Institute is presenting his

testimony.
42

My name is Raymond Stcuyk. I am a Senior Research

Associate at The Urban Institute, where my primary area of

research concerns the housing problems of elderly Americans. I

am also a member of the Housing Statistics Users Group, which

consists of individuals interested in facilitating the flow of

information between governmental producers of data on housing

and interested users, including city planners, public interest

groups, and research organizations.

I appreciate the opportunity to comment on the effects of

the modifications to the 1990 decennial census as proposed by

the Office of Management and Budget (OMB) in its letter of

September 16, 1987. Because of the interests of this

committee, I will focus my remarks on the potential impacts of

the suggested changes on the ability of planners at the local

level to define the housing needs of the elderly and design

programs to meet these needs.

As you know, OMB has suggested major changes both to the

content of the so-called short form items which are asked of

100 percent of households and to the sampling rate for the socalled long form. In particular, OMB suggested shifting seven

housing questions from the short form to the long form,

deleting three questions on heating equipment and utility

payments from the long form questionnaire, and cutting the long

form sample from about 17.7 million households to 10 million

households. I understand that in November OMB modified its

•1-
43

position on the utilities questions to allow an abbreviated

question on utility payments, but only foe renters.

For program planning at the small area level, the damage

caused by the content and sampling changes will reinforce each

other thereby producing very deleterious effects. First, the

seven housing items will no longer be available in the "block

statistics." So analysis of many issues at the block level

will simply not be possible. Second, even at the census tract

level, because of the very large cut in the long form sampling

rate, we cannot be certain that the housing data will continue

to be available. Because of census confidentiality

requirements, the Census Bureau will have to suppress data where

the number of observations in a given "cell" is small. This

will be an especially severe problem for reporting certain data

items, including such items as the housing attributes of the

elderly and all data reported separately for blacks and

hispanics.

In summary, I believe that shifting the housing questions

to the long form would be a very serious mistake because it

would cripple much of the small area planning that cities must

be able to do. Deletion or modification of the three heating

and utility questions is also clearly wrong because it will

make it impossible to identify true housing costs. The effects

of the proposed change in the sampling rates for the long form

will further undermine small area planning by sharply cutting

the information available.

•2•
44

Analysis with the Small Area Data

1 would now like to give a couple of concrete examples of

planning for housing of elderly Americans that would be

effected adversely by OHB's proposed changes. In these

examples I will concentrate on the effects of the loss of

information from the 100 percent enumeration that would result

from deleting the seven housing questions.

Example 1; Home Repair Programs. Many American cities

are now operating home repair programs which assist elderly

homeowners, often those with low incomes, to keep their housing

in good condition. The programs result in better housing

for the elderly and improved neighborhood conditions which are

often important in stabilizing inner city areas. Studies of

such programs have found that to be successful in attracting

elderly homeowners to participate it is necessary to speak

individually to the homeowners to explain the program and allay

possible fears about strangers coming to their homes to make

repairs. To keep program cost under control it is necessary to

target these outreach efforts to small geographic areas where

repairs are most likely to be needed.

The census block data have been extraordinarily useful for

this purpose, since they identify where elderly persons are

living, the distribution of households between owners and

renters, and the distribution of house values in the

_-3__
45

neighborhood. These latter data are useful because homes with

lower market values point to housing more likely to be in need

of repair. Additionally, the census block data indicate how

many units lack full plumbing facilities•a very useful shorthand measure of condition of the housing stock. Based on these

data, neighborhoods with concentrations of elderly and

homeowners can be identified as "high payoff" areas to bring

into the program first; later, after word has spread informally

to areas with fewer elderly homeowners, areas more costly to

canvass can be added to the program.

Under the OMB proposal none of these data items except the

presence of elderly persons and the split between owners and

renters would be available in the block level data. Instead,

planners will have to rely on data for the much larger and more

heterogeneous census tracts.

Example 2; Market Analysis for Special Housing

Arrangements. As this committee is well aware, a number of new

housing types are becoming popular with the elderly. These

include such options as small group homes, continuing care

retirement communities, and congregate housing facilities.

While in many cases these facilities are associated with state

and local government efforts to provide additional options

combining housing with support services in ways that meet the

variety of needs and desires of the elderly, often private

providers are also entering the market. We also know that the

elderly place a very high premium on being able to remain in

•4 •
46

their own neighborhood, close to their friends and church.

Housing facilities that may be perfectly attractive on an

objective basis can have problems renting up, if they are not

well located in terms of a substantial elderly population of the

right income level. Softness in some markets for Section 202

housing is a sharp reminder of this fact.

Therefore, small area analysis is critical to proper

siting of such facilities. Several items in the Census block

data can be very helpful in this regard: the number of elderly

present and the range of house values and rents. The latter

are good indicators of the income and ability to pay for a new

type of housing in the neighborhood in the absence of income

data. Combined these items help the market analyst target

potential sites for new housing solutions efficiently. Beyond

these data, the 100 percent items on condominiums and

congregate housing (some meals included in the rent paid) are

also important in helping judge the overall market. Because

the incidence of condo and congregate units is very low,

gathering them on a sample basis is especially risky in terms

of reliability.

Under the OMB proposal the information on house values and

rents will not be available at the block level. Moreover,

information on condos and congregate units will be obtained on

a sample basis only, thereby undermining their reliability at

the town and city level.

Example 3: Identifying Housing Needs. Besides the

__5__
47

housing programs just discussed, planners require information on

the distribution of housing needs in their communities on a fine

geographic basis for many other analyses. In 1980 one could

identify overcrowded and deficient units (as indicated by lack

of plumbing) from the published block data reports. Use of

these data was recommended in a recent planning document

prepared by the U.S. Conference of Mayors, Assessing Elderly

Housing; A Planning Guide for Mayors and Local Officials. This

type of analysis will simply not be possible if the OMB

proposals are adopted, because the plumbing and number of rooms

questions will not appear on the short-form. Hence, even rough

analyses of housing needs on small area basis will necessitate

special, locally financed surveys.

In addition to looking at housing conditions in 1990, the

loss of the housing data items proposed for elimination by OMB

will destroy the possibility of doing effective trend analysis

for small areas. If there is one thing that we have learned

from studies of neighborhood dynamics, it is that change must be

monitored closely. Trends in house values and rents, shifts in

the homeownership rate, crowding and the related problem of

exclusive use of plumbing facilities are important indicators of

a neighborhood's health. The block statistics are critical to

identifying troubled neighborhoods that merit more intense

observation by local planners. If the seven housing questions

are shifted to the long form, the only trend that one can

compute for 1980 to 1990 for small areas will be shifts in the
48

homeowner ship rate.

Use of the Small Area Data

It has been claimed that the types of analysis just

described are done only infrequently, the implication being

that the cost of including the housing questions on the short

form cannot be justified on the basis of a few exotic analyses.

This claim is simply wrong. After the General Accounting

Office recommended dropping the housing items from the short

form (GAO/GGD-866-74BR, May 5, 1986), Congressman Dymally asked

GAO to undertake an analysis of the actual use of these data.

In its follow-up report, GAO reported that indeed these data

are used frequently and extensively by local governments

(GAO/GGD-87-56BR, April 1987). OMB misused these studies in

its letter suggesting shifting the housing questions to the

long form, in which only the first of the two GAO reports was

cited.

Beyond the GAO report, there is additional evidence from a

survey of its members undertaken by the American Planning

Association (APA). The survey results show widespread use of

the small area data for such diverse activities as housing

occupancy code enforcement and locating public facilities such

as adult day care centers. Additionally, survey respondents

noted that many tracts on fringes of urban areas are so varied

internally that only the block data provide meaningful

information for planning purposes. (The results are summarized
49

in a letter from the APA to Congressman Garcia, dated October

24, 1986, available from Nancy Willis at the APA.)

Dropping the Utility Questions

OMB has proposed dropping or reducing three housing

questions from the long form: two on the type of heating

equipment used and the fuel used for heating would be dropped,

and a four part question on the household's payments for

utilities would be dropped for homeowners and for renters only

inquire as to whether they paid separately for various utilities

but not ask about actual expenditures. Information on the type

of heating equipment has long served as a useful measure of

housing quality, with unvented systems•such as kerosene burning

space heaters•being a clear indicator of lower quality

conditions in most parts of the country.

On the other hand, the data on utilities' cost have been

important for measuring total share of income being devoted to

housing. Without these data, it will be impossible to compute

the standard indicators of affordability problems for the

majority of cities and towns in this country, i.e., any place

outside the 66 areas covered by the American Housing Survey

(AHS). Obviously, no small area analysis would be possible. In

addition, HUD would lose the "benchmarks" it has obtained from

the census in the past for setting the Fair Market Rents

(outside of areas covered by the AHS) for the Section 8 Existing

and housing voucher programs. HUD would also lose the use of
50

measures of the share of households with excessive housing

expenditures In formulas allocating program funds; the Rental

Rehabilitation Program Is one program using this factor In Its

allocation formula.

True, there have been some reliability problems with these

questions, which the Census Bureau Is hoping to mitigate with a

change in their wording. Moreover, in the past the Census

Bureau has used the 100 percent short form data on contract

rents in a procedure that improved its estimates of gross rents,

i.e., contract rents plus utilities. In any event, the census

data are very likely to be much more accurate for small areas

than housing cost data obtained through imputation procedures.

Shifting the contract rent question to the long form and

dropping or modifying the utilities question as proposed by OMB

would very seriously undermine the quality and usefulness of the

rent data. OMB's proposal seems especially ill-timed, since the

share of income devoted to housing has been rising consistently

over the last several years, and indeed has reached crisis

proportions for some types of households in some neighborhoods.

Cutting the Long Form Sample

Finally, I want to make a couple of observations about the

proposal to cut the sample size for the long form. The most

critical issue for small area analysis is the point at which

data will have to be suppressed even at the census tract level

because of confidentiality requirements. In 1980 the rule for

__9_-
51

suppressing the data was that there had to be at least 10

household or 30 person (weighted) observations available for

the item to be reported. So, for example, to report contract

rents for a tract, at least 10 renters would have to be in the

tract. The OMB recommendation would change the average

sampling rate from about 17.7 to 10 million households.

Obviously, with the smaller samples, the cut off for suppression

would have to be raised if the user is to place equivalent

confidence in the 1990 figures as he did in the 1980 data. So

perhaps in our example 20 renters would have to be present for

any data to be reported.

Especially at risk of suppression are the separate data

published for blacks and hispanics at the tract level and the

separate data on housing attributes of the elderly which were

published in 1980 for tracts (table H-7). The later have been

widely used by those dealing with elderly housing issues at the

local level.

I should note that the Housing Statistics Users Group

commissioned a study of the impact of the revised long form

sampling rates by Harold Nisselson of Westat, Inc. on data

reliability. This paper was completed in December 1987 and I

believe has been supplied to the Committee. This analysis,

as well as the Census Bureau's internal analysis, indicates

reliability problems would be seriously exacerbated by

cutting the sample size as recommended by OMB.

•10-
In summary, I am opposed to all of the proposed OMB

changes in the 1990 decennial census because of their

implications for the ability to do small area planning for

meeting the housing needs of the elderly in addition to their

more general adverse effects. From the perspective of a data

user, OMB's action at this late stage in the planning for the

1990 census seems capricious and mistaken. Thank you.

•11-
53

Chairman ROYBAL. The Chair now recognizes Ms. Becker.

STATEMENT OF PATRICIA C. BECKER, PLANNING DEPARTMENT,

CITY OF DETROIT, MI

Ms. BECKER. Thank you for the opportunity to appear before you

this morning. I have submitted for the record a document entitled

"The Office of Management and Budget's Changes to the 1990

Census: A Critical Commentary," written in cooperation with the

Council of Professional Associations on Federal Statistics and the

Housing Statistics Users Group. It reviews, in some detail, the

harmful nature of the changes being imposed.

[See Appendix IV, p. 121 for material submitted by Ms. Becker.]

Ms. BECKER. I will highlight them here and provide some examples of specific effects on programs designed to serve the elderly.

My focus will be the impact on data for small areas, that essence of

the census data base that is so important to planning and decisionmaking at the local level.

As we know, OMB has ordered changes in three major categories: moving most of the short form housing questions to the long

form; deleting some long form items; and cutting the number of

sample housing units by 40 percent. These changes are not independent of one another. Rather, they operate together to hurt the

data base collectively even more than the measure of each taken

by itself.

Sampling errors, as we know, get larger as the number of observations gets smaller. The problem is especially critical when the

number of observations is small to begin with, say, under 500. A

decrease in the sampling fraction is not a major problem when

looking at large populations such as States and major metropolitan

areas. The trouble comes when trying to use the data for small

areas, census tracts or small groups of tracts within a city, small

rural counties, individual communities. Yet this is the level at

which most planning for government activities takes place.

The problem is compounded when we want to use the census

data base to help us plan programs for demographic subgroups.

The elderly, who constitute about one-sixth of the total population,

are such a group. If it is then desirable to divide the group further,

by race, for example, or by age, the "young old" and "old old," we

end up with an even smaller number of observations on which to

base our conclusions.

Let me turn now to some specific examples of data use in planning programs for the elderly. The Detroit Area Agency on Aging,

as required by the Older Americans Act, prepares an Area Plan for

each 3 years of its operation. This agency serves the city of Detroit

along with eight suburban communities; collectively, about 225,000

people aged 60 and older lived here in 1980. Their needs varied

widely, since some of the suburban communities are among the

most affluent in the Nation, while some subcommunities in Detroit

are very poor.

To determine relative need, the agency applies a formula which

includes three factors. Thirty percent of the weight is given to the

aged population in poverty. About one-third of the agency's social

service budget is allocated to the in-home services program. The
54

ranking of need that emerges from application of the formula determines the amount of money to be spent on in-home services in

each of the 59 communities and subcommunities in the agency's

service area.

One of the major in-home services provided under this program

is home maintenance. In the Detroit area many senior citizens

prefer to stay in their own paid-for homes as long as possible. Often

they are the first generation of homeowners in their families, and

owning property marks a real economic achievement.

At the same time, with limited retirement incomes and reduced

physical capacity, assistance with routine home maintenance

chores becomes a necessary service to maintain both quality of life

for the residents and the structure itself in good condition.

Under OMB's restriction of a 10 million sample nationwide,

almost all of the Detroit area communities and subcommunities

will be sampled at a rate of 1 in 10 rather than 1 in 6. Error levels

on the poverty data will rise by an average of 40 percent. Significant misallocation of the limited resources for in home services

could be the result.

Another activity currently underway in Michigan is a demonstration program called "Let's Go." The idea here is to provide

curb to curb, or door to door, if necessary, transportation service

for the elderly. Priority is given to trips for medical purposes.

Planning for this program requires measurement of need at a geographic level appropriate for service delivery. In Detroit, that

would be an area of about a quarter million people. In rural areas,

the program would be organized by county, and service delivery

planned for considerably smaller population groups.

The program planners need to know how many elderly people

there are, how many have no automobile available, and their

income and poverty levels. Again, with a reduced sample, the error

levels in the required tabulations will be so high that significantly

wrong service allocation decisions could be made.

Another program for the elderly is Retirement Service Center

Housing, a 221(d)4 congregate housing program. HUD area offices.

State housing development authorities and private developers,

along with the consultants who assist them, all have to make decisions and recommendations based on an assessment of need levels

for this form of housing. At 1980 sampling rates, a total population

base of about 200,000 is needed to provide enough observations of

elderly households to analyze need and project demand.

With the mandated cut in the sample, the total population level

would have to go up to about 350,000 before reasonably reliable

data would be available. Only 5 of Michigan's 83 counties are this

size. We should be working to improve the data base for planning

these types of programs, rather than harming it.

An important point to remember for all uses of census data is

that, once published, census data take on a life of their own. The

frequencies observed in the sample questionnaires are arithmetically expanded to represent the total population. The actual number

of observations is buried in the appendix, and few data users pay

any attention to errors. Most operate on the assumption that the

published numbers are correct.
55

For this reason, it is very important that data producers, both in

the Census Bureau and outside, be "watchdogs" on this issue, and

maintain strict standards for acceptable publication. If this is done

responsibly, some tabulations that were available in the 1980

census should not be prepared for 1990.

Almost forgotten in the debate over sample size is the question of

moving the 100 percent housing items to the sample. As indicated

in my written paper, to eliminate these questions from the short

form while, at the same time, collecting them only from a smaller

sample, amounts to a "double whammy."

Rent and value are our only measures of socio-economic status at

the block level. The items on complete plumbing and number of

rooms provide the only clues to housing quality at the block level.

Condominium status is an integral part of the tenure/value relationship. The question regarding inclusion of meals in the rent is

essential to planning for congregate housing, yet must be tied to

individual facilities at the block level in order to be interpreted

properly.

Groups of blocks such as voting precincts and small neighborhoods can be studied only by aggregating data at the block level.

The sample data for block groups and small communities, previously available in summary tape format, will not be reliable on a 1 in

10 sample. Thus, analysis for these small areas will depend on 100

percent items. Many uses of the census data base, taken for granted by users for decades, will be rendered impossible if the short

form housing data are not available.

OMB has argued recently that sampling error is already very

small in an efficiently allocated sample of 10 million households.

No statistical evidence is presented to back up this contention. It

has also stated that the sample must be cut in order to maintain

quality, because there will be an inadequate workforce availability

to conduct the necessary followup for nonresponse and failed edits.

While certainly there are nonsampling errors which must be considered, the plain statistical fact is that fewer cases mean higher

errors, regardless of anything else. The plain fact on the workforce

availability argument is that, in most parts of the country, there

are a great many unemployed persons who can be trained to work

on the census. The plain fact is that when data are to be used to

plan and make decisions in small geographic areas and for small

demographic and housing subgroups, the difference between a nationwide sample of 1 in 6 and 1 in 10 is very significant indeed.

The Bureau of the Census has spent several years planning the

1990 census. Users throughout government and the private sector

were consulted in a variety of forums. Tradeoffs were made between data needs, respondent burden and cost. The result was embodied in the package submitted to OMB for clearance in June of

last year.

It seems unreasonable that all of this work should be turned

around by a small group of people with considerably less experience and expertise in the matter. With a modification in implementation of a variable sampling plan, we need to go back to where we

were 8 months ago. We need a good 1990 census, useful for all the

purposes to which the data are put. If OMB has its way, that will

not be the result.
56

Chairman ROYBAL. Thank you, Ms. Becker. Mr. MacRae, I'm

going to start off the questioning and then ask each member of the

committee to take time also to question each and every one of you,

if they so desire. But I think that the case that has been built

against your intent to reduce the sampling is quite clear.

For example, Mr. Young has stated that the proposed 1990 housing census content was less than 1980. Well, we know that, but

then it goes on to say that it was the briefest since 1950. In other

words, what you are attempting to do, I believe, is to go back to

1950; but this is 1988, and we're talking about the census of 1990.

Going backwards is not my idea of progress.

Mayor Holland said the content and sample size issue would

have a potentially debilitating impact upon the cities of this

Nation. This comes from the mayor of a city, an individual who is

expert in the functioning of a municipal government, and who understands what the census could mean if not taken correctly.

Ms. Turner said this: "I believe that shifting the housing questions to the long form would be a very serious mistake, because it

would cripple much of the small area planning that cities must be

able to do.'

In other words, I believe from that testimony, or what I get from

that, is that cities would suffer the consequences.

Ms. Becker said, moving the 100 percent housing questions to the

sample is a serious mistake, and then goes on to explain why.

So my question to you is this. What was the rationale for OMB's

proposal to limit the sample size of the long questionnaire's form to

10 million housing units? Why the reduction?

Mr. MACRAE. Mr. Chairman, I would like to ask Ms. Telia to respond to parts of this.

Chairman ROYBAL. MS. Telia, would you please answer the question?

Ms. TELLA. Mr. Chairman, the question is, what was our rationale?

Chairman ROYBAL. Yes.

Ms. TELLA. If I could back up just a second and explain exactly

what we did, because some strange numbers have been floating

around in the past few minutes.

Chairman ROYBAL. Yes, but there must be a reason for having

done it, and that's what we want to know.

Ms. TELLA. Yes. The initial proposal of the Bureau of the Census

was to sample 1 in 6 households across the country, that is, give 1

out of every 6 households across the country•in every sampling

area of the country•the long form. This would have resulted in a

total national sample of roughly 16 million households. Not 17 Vz,

not 19, but 16.

The Office of Management and Budget recommended that,

rather than fielding this fixed rate sample of 16 million, the

bureau instead design and dress rehearse a variable rate sample,

that is, a sample in which the sampling fraction would differ

among sampling areas, so as to give samples of approximately

equal size and precision for all sampling areas across the country,

whether they be central city sampling areas, rural sampling areas,

small local jurisdictions.
57

We further recommended that this variable-rate sample be no

larger than 10 million households. The rationale was the following:

A variable rate sample is a great deal more efficient than a fixed

rate sample.

Chairman ROYBAL. Why is it more efficient? Everyone seems to

disagree with that. Will you explain, why would it be more efficient?

Ms. TELLA. I don't think, Mr. Chairman, there is any disagreement that a variable rate sample is more efficient.

Chairman ROYBAL. AH right. You tell us.

Ms. TELLA. Because when you calculate sampling error, you find

that samples of approximately the same size in all sampling areas

will give you approximately equal levels of precision, that is, sampling error. The fixed rate sample would have given you very small

samples in the least densely populated sampling areas, that is,

small local jurisdictions and rural tracts.

In many cases, we believed that a 1 in 6 sample for that type of

area would not be large enough to enable meaningful data to be

published for those areas.

On the other hand, it appeared to us not to be necessary to

sample as many as 1 in 6 households in very densely populated

sampling areas, that is, central cities; because there are a whole lot

of people concentrated there. They tend to be fairly homogeneous.

That is, the households and housing units tend to be more similar

in these areas than they are in sparsely populated, rural areas.

If one has a sample of fixed size to allocate in order to get the

most precise estimates across the country, the most efficient way to

allocate that sample is through the sort of variable rate sample

that we recommended to the Census Bureau.

I might add that the bureau was quite ready to field a variable

rate sample. That was not an area of dispute at all between the

Census Bureau and OMB. The issue being raised here is, should

the variable rate sample be limited to a maximum size of 10 million households?

Our argument is yes. The variable rate 10 million household

sample will give greater precision, lower sampling error for rural

areas and small local jurisdictions than would the design of the

Census Bureau initially proposed.

There will be an increase in sampling error for urban sampling.

There is no denying that. Someone mentioned here earlier that the

sampling error would be doubled. It's important to realize that

when 1 percent goes up to 2 percent, that's a doubling. Our view is

that the sampling error already is very low, that even doubled for

urban areas, the sampling error is smaller than nonsampling error.

The Mayor made the statement that sample surveys only give

you estimates, whereas the census gives you an accurate count.

Ideally, this is so, but one has to be aware that there is a great deal

of error in census data that arises not from sampling•the fact that

we're only asking questions from 1 in 6 or 1 in 20 people•but because these people don't answer some questions, or they don't understand the questions and they give an incorrect answer, or the

question may be asked in a range•for example, "what is the value

of your house," and you check a range.
58

These are all sources of error that has nothing to do with the

size of the sample.

Chairman ROYBAL. Well, Ms. Telia, what I'm really concerned

about is the fact that you're actually not asking the specific important questions. The intent is to leave out at least four important

questions. The number of housing units at this address is one of

them, the access to the living quarters, the number of storage in

the structure and presence of an elevator, and the fuel used for

cooking.

It is my understanding that fuel utilities, for example, are part

of the rental cost and are subject matters that I believe should be

included in the census. They always have been. Why leave them

out now?

Ms. TELLA. Three questions, only three questions were eliminated

from the census altogether•three questions relating to household

energy use and cost, utility costs, that have been asked in past censuses. The reason that OMB recommended that they not be asked

in the census in 1990 is that when the utility cost questions have

been asked in the past, there has been a very large bias. The

Census Bureau itself looked at the accuracy of the response to this

question and found that there was a very large bias, so that the

data were not accurate.

Chairman ROYBAL. Well, if you don't get the response that you

want, you then don't want to ask the question. Is that it? I don't

understand what you're saying, Ms. Telia. Perhaps it will be a

little clearer if we ask Ms. Becker to respond to some of the things

you said about the sample size reduction and so forth. Let's get into

that for just a moment.

Ms. TELLA. AS Mr. Wright's testimony indicates, OMB has been

working closely with the Department of Energy and the Department of Housing and Urban Development which would like to have

that energy cost data, in an effort to find a way, another way, to

get HUD more accurate data for their purposes.

It seems to us that there's no virtue whatsoever in producing

very inaccurate data. What HUD needs is accurate data on household utility costs, and we are working very hard to find a way to

get HUD that data.

Mr. HOLLAND. Mr. Chairman, it was I who made the statement

that, with regard to the increase in the error being 100 percent.

That's based on opinions of researchers and statisticians who have

carefully looked at this issue but it just so happens that before I

entered government, for 4 years I worked for a research corporation as a field supervisor and as a research analyst, and then

served as Associate Director of Princeton Research Service, both

market and opinion research firms. The sample is critical, obviously, to accurate analysis and, certainly, with something as important as a decennial census, you cannot talk about decreasing samples.

I agree that a variable approach is more efficient when it can

validly be used, but you increase the sample. Also, it's important to

note that, while in the more densely homogeneous areas, there's

less likely to be error. The fact is that across this country, especially in the Northeast, a lot of gentrification has taken place, and for

the first time in decades the mix of the central cities is in flux. I
59

think we can't, therefore, take the traditional view with regard to

the central city universe.

With regard to the interviews, if there's a bias, then, obviously,

you've got to improve the interviewing technique. Testing the questionnaire and training interviewers is as critical as is the percentage of error and all the equally important components.

You talked about some of these questions not being so critical.

What's more important than energy? The Nation just went

through a crisis, and we want to make sure we don't go through

another one. In the central cities, one of the crucial programs is

the winterization program.

So I see those questions as even more important.

Chairman ROYBAL. Thank you. Mayor. I'd like to hear from Ms.

Becker with regard to the sample size.

Ms. BECKER. I think the point that OMB is not recognizing is

that the data are used for small areas for tracts, for communities

of 10-15,000 population. That's where the planning gets done, and

that's where we need accurate samples.

They are claiming that nonsampling errors are larger than sampling errors. That may be true when we're talking about data at

the State level and up, but not when you're talking about data

from the small areas, because sampling errors increase exponentially. Rather than remaining relatively constant in proportion to

the total response. So when we get down to fewer cases, the sampling errors greatly exceed the nonsampling errors, and it's unreasonable to think that we're going to have data that we can use.

Experience tells you that in the kind of work that I do all the

time where I look at tabulations, detailed tabulations for the city of

Detroit, and I look at the tables, you can see bad data in the tables.

You can see where there are not enough cases, and you do not use

that level of detail in planning.

Now what's going to happen is that planning will suffer with this

overall sample of 1 in 10. A great many more tabulations are going

to be bad, are going to be unusable, unreliable, and will not have

the data that we need to do the planning to allocate scarce resources, the money that we have to spend.

Chairman ROYBAL. Mr. Young, what about sample size? What is

your opinion?

Mr. YOUNG. Mr. Roybal, let me try to explain some of the problems that I see in this. If we look at a problem in American housing of overcrowding, something that may occur nationwide in about

10 percent of the homes, one of the things that a city or metropolitan area wants to do is to pick out the census tracts•those are the

chunks of land of about 3,000 to 5,000 population•where there is

the most overcrowding, so that they can look at housing needs,

housing code enforcement, and all the related problems that beset

a city government in looking for housing solutions.

When you take the 1980 data, you can rank, not the tracts which

may consist of 30, 40, 50 blocks or up to 100 blocks but you can

take the individual blocks from the 1980 data and rank them from

the most crowded to the least; and that ranking is 100 percent data

subject to no sampling errors. Basically, it is as accurate as a

count.
60

What we will be faced with in 1990, if these OMB cuts go

through, is to look, not at block data, but at tract data. The 10 percent item will have a sampling error of about 25 percent, which

means that there are two changes out of three, if I look at a published 10 percent number, that the truth is someplace between 7.5

percent and 12.5 percent. If you use the confidence limits that the

bureau currently uses in all its current surveys, 90 percent, you

must say that there are 9 chances out of 10 that the true value lies

between 6 and 14 percent.

Now, if you look at all the tracts in cities, most of the overcrowding is within that range. What you're faced with is that you can't

tell which tract is more overcrowded than the next except in the

most extreme cases. You are now unable to rank the parts of your

city in terms of this problem.

The plumbing situation gets worse, as does any analysis where

low rent or low value housing is concerned. The ability to rank

areas in the city, to try to focus, to pinpoint where you want to do

your housing programs is lost. The geographic specificity that we

had in 1980 is no longer with us. In 1990 we will get a blurred sort

of homogenized number.

One of the other important things that you have to remember is

that housing problems like overcrowding and a lack of plumbing

occur in concentrated clusters, usually in blocks or individual

buildings. When you look at the data for a whole tract, they are

averaged out, and this hurts the ability to distinguish between

tracts.

Taking the housing items off the 100 percent, and decreasing the

sample is a critical loss that really wipes out the usefulness of the

housing data for intraurban analysis and planning.

Chairman ROYBAL. Thank you, Mr. Young. The Chair will now

recognize the Chairman of the Subcommittee on Housing and Consumer Interests who is the Cochair of this hearing with me. It is

with a great deal of pleasure that I now yield time to Mr. Bonker.

Chairman BONKER. Thank you. Mr. Chairman, I want to commend you for cosponsoring these timely hearings so we can get a

better sense of what OMB is up to with respect to the upcoming

census.

I'm sorry that Mr. Wright is no longer here to respond to the

questions we have, but I can appreciate that the people he has left

are fully capable of rationalizing what OMB is up to. Indeed, I'd

like to lead off with that question.

It seems to me that OMB has enough to do these days without

getting into the census. On what basis are you dipping into census

data and census questions, and all that goes into that very extensive, detailed process? I'm sure you can cite an authority. What is

it, the Paperwork Reduction Act?

Mr. MACRAE. That's correct, sir.

Chairman BONKER. SO your main objective here is to reduce paperwork, not to get into policy considerations?

Mr. MACRAE. Well, the Paperwork Act asks that we not only

look at reduction of paperwork but at the quality of the data that's

collected. So it's not just a mindless "let's whack the paperwork

down;" we're also interested, as is the Census Bureau and I'm sure

everyone else here, in the quality of the data.
61

Chairman BONKER. Well, that's an adequate response, but we all

know that OMB is out there with an axe to cut up everything that

they can. And here where you have the experts in the government

on the census, you're coming in and, 1 think, attempting to compromise their work by rewriting questions and trying to narrow the

focus of the census. It's disturbing that we even have to have this

hearing; that we have to go through this. I mean, I've got other

things to do than having to spend time on this whole question of

the census.

Mr. MACRAE. Mr. Chairman, we also have other things to do, but

we do feel we have a responsibility under the Paperwork Act, and

we have had long conversations with the Census Bureau. The initial proposal was 16 million households for the long form. We discussed with them this whole question, and they thought it was an

excellent idea, for a variable-rate sample.

There is continuing discussion and debate on whether we should

go to 10 million households, 16 million households. 17.7 is the

figure they are now suggesting, and we've asked for further analysis within that range.

Chairman BONKER. Seems to me you could save a lot more paperwork just by staying out of it.

Mr. MACRAE. Well, that might be, Mr. Chairman, but we do have

a responsibility under the Paperwork Act, and we can't absolve

ourselves of that by just staying out of it.

Chairman BONKER. DO you have any idea how many manhours

OMB has put into this matter?

Mr. MACRAE. Probably a fair number. In responding to what you

were asking, why are you doing this, we tried to explain it. I would

also like to emphasize that we are at the dress rehearsal stage, and

the law provides that the Census Bureau inform the Congress in

April of this year, and whenever they ask, of what it plans to do

with regard to content of the 1990 census itself.

We are awaiting•and we've asked the Census Bureau to move

as quickly as possible•the results of the dress rehearsal. We believe that, when we have those in hand, we, the Congress and, as

Mr. Wright said, others, can make an informed choice of what

should be in the 1990 census.

Chairman BONKER. Well, since you brought up the dress rehearsal, now when do you expect it to be completed?

Mr. MACRAE. We don't have a firm fix yet from the Census

Bureau. They are launching the dress rehearsal in March. When

they will have the results of the analysis I'm not sure.

Chairman BONKER. Would you say that it would be anytime

before June?

Mr. MACRAE. I doubt it will be that soon. After all, they will

have just conducted it in March. It's going to take a while.

Chairman BONKER. Well, our understanding is that the Census

Bureau will not have the data into the computers until August. Is

that your understanding?

Mr. MACRAE. They have not said to us when they will have the

information in the computers.

Chairman BONKER. Well, we have a document from the Census

Bureau that shows that the information that you will consider

83-79A 0
62

before making any final decision regarding the census will not be

available until late in 1988.

Mr. MACRAE. 1988 or 1989?

Chairman BONKER. 1988.

Mr. MACRAE. When in 1988?

Chairman BONKER. Late.

Mr. MACRAE. Well, we obviously can't consider anything until

we have something in hand.

Chairman BONKER. That's the whole point, you know, whether or

not you would be prematurely making determinations before that

data is in the computer and we have the information.

Mr. MACRAE. Absolutely not. We would not.

Chairman BONKER. Mr. Chairman, I wonder if we can hold the

record open so I can submit additional questions to OMB in writing.

Chairman ROYBAL. The record will remain open for an additional

2 weeks. Questions can be submitted in writing. I'd like to request

that the answers be submitted to the committee before the end of

the 2 week period.

Mr. MACRAE. We will so comply, Mr. Chairman.

Chairman ROYBAL. Thank you.

Chairman BONKER. I thank the Chairman and have no further

questions.

Chairman ROYBAL. MS. Bentley.

Ms. BENTLEY. Thank you, Mr. Chairman. I, too, want to commend you for having this hearing, and I have a statement that has

been sent to be included in the record.

Chairman ROYBAL. Without objection, it will be the order.

Ms. BENTLEY. I'd like to ask OMB, before notifying the Census

Bureau about the transfer of the questions from the 100 percent

questionnaire to the sample form and deleting the three utility

questions and changing the size and structure of the sample population, what type of public hearings did you hold?

Mr. MACRAE. We held no public hearings.

Ms. BENTLEY. Did you meet with data users?

Ms. TELLA. We had a number of meetings with

Ms. BENTLEY. Would you put the microphone on so we can hear

you, please.

Ms. TELLA. During the period when the dress rehearsal was

under review at the Office of Management and Budget, from, midJune to mid-September, we had a number of meetings with Federal

agencies who are users of census data, who use census data for the

administration of their programs, to make sure we had a firm fix

on what they could not do without, what they wanted, what they

needed, and so forth. We did not have meetings with, as I recall,

members of the public. Nobody indicated

Ms. BENTLEY. YOU did not have meetings with members of the

public.

Ms. TELLA. I was not present at any. I'm not aware that anyone

wanted to meet with us.

Ms. BENTLEY. Well, did anyone know about it?

Ms. TELLA. Yes. They did know about it.

Ms. BENTLEY. They do now.
63

Ms. TELLA. Agencies are required by law to put a notice in the

Federal Register at the time that they submit any paperwork to

OMB for review. So that notice was given. Further, in the course of

our review we put a notice in the Federal Register indicating the

type of issues that we were concerned with, the type of questions

we were raising. We did get quite an influx of mail from members

of the public.

Ms. BENTLEY. Mr. Chairman, I'd like to have a copy of that

notice in the Federal Register included in the record so we can see

exactly what the wording was, because I would presume that

maybe a lot of people didn't know what was going on.

Chairman ROYBAL. Would you please submit it for the record.

Mr. MACRAE. Yes, sir.

Chairman ROYBAL. Thank you. Without objection, it will be ordered.

[The Federal Register notice follows:]
64

Tuesday

August 25, 1987

Part IV

Office of

Management and

Budget

Review of the "Dress Rehearsal" for the

1990 Census of Population and Housing;

Notice
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»116 Ftdwl Regirtt / Vol. g No. 1M / Tuwday. Augutt 25. 1967 / Notlcei

thoae household! that receive the long accuracy of the cemui count and the ID Incomplete or othenwite defictenl

form. OMB hat asked the Census Bureau reliability of the demographic data that that a follow-up was required. Before

to consider the possibility of dividing are collected in the census. The high approving plans for the 1990 census,

the long-form questions into two or mor« rales of "failed edlla" in the 1970 and OMB would like to be sure that careful

queslionnairea. so as to distribute the ieeo censuses (the percenlag* of attention has been paid to all aspects of

burden more equitably. returned forma that did not meal the d•

,

• collection that could affect the

S. /»IA« length ofthe proposed Census Bureau's edit criteria and quality of response.

quesLonnaires. particularly the long therefor* had to be followed up) suggest Airthorily: 44 UAC 3304.

form, likely to have any adverse effect thai in the recent past respondents have Wandy L Cramm.

on the quality ofrespongeT experienced substantial problems filling AdministrvtorforInfomtaiionandlte$iihu>fy

OMB'i concern about queslionnain out forms completely and accurately. Affair*.

length and content reialea not just to For axample. In 1980 45 percent of ihe |FK Doc. r-l9S74 Filed » M-a7: a45 mm\

burden but. even more important, to th« long forma that wera mailed back wera BUAN COM IIM-SMS
68

Ms. BENTLEY. HOW will local communities know where to locate

police and fire stations, health clinics and any number of other facilities when block level data no longer will be available?

Ms. TELLA. Block level data will be available for all the data collected on the short form. The basic population data that are collected on the short form will be there for every single person in the

population. So you will know down to the block•down to the

smallest unit for which the Census Bureau publishes data•how

many people are there, what age they are, what sex they are, what

race they are, what ethnic background.

Ms. BENTLEY. Age?

Ms. TELLA. Yes.

Ms. BENTLEY. SO we will be able to determine where senior citizen centers and Section 202 housing should be located from that?

Ms. TELLA. Absolutely. You will know by block the elderly populations.

Ms. BENTLEY. Are we going to have any block on the census,

tract level data on income and housing costs, so that we can anticipate the potential for homelessness? Or how are we going to anticipate the homelessness in the 1990s?

Ms. TELLA. We at OMB are unable to tell you exactly what data

the Census Bureau is going to publish for what small units. I'm not

sure that question can be answered in general terms. It probably

depends on what small area you're talking about, what subpopulation you are interested in, what characteristics about that subpopulation you're interested in, and also what disclosure control method

the Census Bureau decides to use in publishing data from the 1990

census sample.

Ms. BENTLEY. Mr. Chairman, I, too, would like to submit some

written questions, and I do want to say that I agree with Chairman

Bonker that I think this is one time that OMB has got themselves

in a thing it shouldn't be into. Thank you.

Chairman ROYBAL. Thank you, Ms. Bentley.

I would like to go back again to my original question, and that is

your justification for this, OMB's justification, number one, for

being involved in it. I think I can understand the fact that you do

oversee the Census Bureau; but why the reductions that are being

contemplated in view of the fact that no one seems to agree with

you? How can you justify it?

Mr. MACRAE. That's an interesting question, Mr. Chairman. I

guess our response is that in trying to do our job, and we've probably said this ad nauseum, under the Paperwork Act, we believe

that the questions we've raised and the debate that we have engendered are appropriate to determine what is the best possible and

most efficient census form that can be developed and employed in

1990.

We don't think, for example•that moving questions from the

short form to the long form is a bad step. We happen to believe

that that will help the response rate. People looking at a long form

which the Census Bureau says will take 45 minutes to complete•I

must say I would be most surprised if people could complete it in

45 minutes. But we are concerned that people respond and respond

as accurately as possible and it's for that reason we have recommended shortening the short form. We want to make sure that we
69

count the people out there. That's first and foremost the purpose of

the census it seems to me•the count. That's what the Constitution

envisioned. Over the years we've added other questions, but we

need to count the people. We need to know their age, their sex,

their race, and we want to make sure at the very least that we do

that.

There are many other questions one could add, many useful

questions. There are questions that have been considered, and because of space have been dropped, which would be very useful to

have•for example, about the extent to which people have health

insurance.

There are questions about our Indian population that have been

considered and dropped. Now we weren't the ones to drop this

question. These, in many cases, were questions that were dropped

by the Census Bureau or others.

So we're trying to balance, making sure we count all heads and

making sure we get a good count. First of all, we want an accurate

count. Then, obviously, we want to add these other questions.

That's what we've been trying to do.

Chairman ROYBAL. Well, I tried to follow you very closely, and

have also read the statement that was made by Mr. Wright, and I

thought what you were going to do is justify your position based on

a very famous professor, William Edward Doming. Now I know Mr.

Doming. I have sat in on one of his lectures. So I asked my staff to

contact Mr. Doming to determine whether he had been properly

cited on this matter and Professor Doming said this. "Any quotation that I made regarding smaller sample sizes does not apply to

the census at all, as the census is engaged constantly in sample

surveys. It is a model for the whole world.'

Mr. Wright has said that OMB's rationale is that Dr. Doming

took the position that a smaller sample is preferred. Now Dr.

Deming was in fact very surprised to learn that this remark was

being misinterpreted by OMB to support a reduction in the census

sample size.

I read this into the record, because it is in the record already in

the testimony made by Mr. Wright. In checking with Dr. Deming,

he tells us that he was not consulted on this matter and is not

being properly cited.

Again going into this matter of trying to understand OMB's rationale. You know very well, Mr. MacRae, that OMB does in fact

come before my Appropriations Subcommittee on the Treasury to

justify their budget. They've been coming before that subcommittee

for the last 18 years that I've been a member of that subcommittee.

I don't remember one time, including last year and the year before,

that we ever discussed this particular activity.

We did go into the matter of the reduction in paperwork and so

forth, but not that you were going to go into the census. The question asked by Mr. Bonker concerning what are you doing in that

particular arena, I think, is well taken, particularly in view of the

fact that what you are proposing is something that everyone opposes.

Experts on the other side are telling the committee, this is not

the way to go. Are these people wrong, or are you wrong? Or let's

put it the other way, are you the only one that is right?
70

Mr. MACRAE. I'm not so fortunate, Mr. Chairman, to be in that

position. No, I don't think that they are wrong, and I don't think

we are wrong.

Chairman ROYBAL. That's quite an answer.

Mr. MACRAE. Because I think that the discussion and debate is

appropriate so we can get the best quality product. And one of the

things we have before us is a means of testing our hypothesis in

the dress rehearsal. We believe that the results of that dress rehearsal, which we will review and the Census Bureau will review

and the Congress can review, will give us guidance as to what are

the appropriate questions, and what is the appropriate size of the

sample.

You mentioned that over the 18 years that you have served on

our committee on appropriations this issue has not come up. The

reason in part is that it only comes up every 10 years.

The second thing is, when the census dress rehearsal came up,

we went to our authorizing committees and briefed the staff of the

authorizing committees as to what we would do, and we said do

you believe it's appropriate for us under the Paperwork Reduction

Act to conduct a review of the census in the same fashion as our

review of any other request for clearance under the paperwork act,

and they said, absolutely.

Well, Mr. Chairman, we were not acting improperly.

Chairman ROYBAL. Well, Mr. MacRae, I realize that you have the

authority to do it, but my question is, don't you take into consideration the expert advice of experts in the field?

Mr. MACRAE. We do, Mr. Chairman, and we will as we review

the dress rehearsal.

Chairman ROYBAL. Yes, but you're still cutting out questions.

You still want to reduce it to the point where testimony this morning has indicated that cities will suffer the consequences.

Mr. MACRAE. On the question of cutting out some of the questions altogether, Mr. Chairman, particularly the questions on utility costs, we are seeking to find•we believe we will obtain•much

more accurate data through the efforts of the Department of

Energy and HUD in conducting a different and more targeted

survey to ascertain these costs. We are not just trying to obtain

data. We are trying to obtain more accurate data, targeted data,

than has been obtained in previous responses to those questions.

Chairman ROYBAL. NOW, Mr. MacRae, I want to try to take this

from another angle now and ask Ms. Turner this question, and

then maybe be able to come closer to the response that Mr.

MacRae has given.

Ms. Turner, does the housing statistics users group have a position concerning what the overall content and sampling size of the

decennial census should consist of?

Ms. TURNER. I think that there's widespread agreement with the

census's original proposal in this regard. As has been stated, the

census is the envy of the world in terms of data collection and statistical capability. And while the kinds of substitute data sources

that OMB is suggesting may be available and may suffice for a

State or large metropolitan area, we really have to rely on the

census and their sampling expertise and their 100 percent survey
71

to reach down to the small neighborhood level and collect absolutely essential data there.

Chairman ROYBAL. YOU, of course, are arguing that it should be

larger.

Ms. TURNER. Yes. I agree that we only get this opportunity once

every 10 years to gather national data on critical questions involving the well being of the population, that sacrificing sample size is

clearly a mistake, and moving essential questions from the 100 percent to the sample is another serious mistake, and the two mistakes interact with one another to reduce the overall reliability of

what you can do with this data at the neighborhood level.

Chairman ROYBAL. All right, Ms. Becker, do you agree with that?

Ms. BECKER. Yes, absolutely.

Chairman ROYBAL. Mr. Young?

Mr. YOUNG. Absolutely. I would like permission to add one thing

that is disturbing me greatly about this morning's testimony. I'm

no longer with the bureau, but I remember the 1960 census, the

1970 census and the 1980 census. Timing is crucial in the preparatory work. The amount, the number of questionnaires that have to

be printed is staggering. I would suggest strongly that you ask the

Census Bureau to review its timetable for printing, for assembling,

for addressing and distributing the questionnaires to the Post

Office in view of this OMB testimony that until there are results

from the dress rehearsal that can be analyzed they cannot make

content and sampling plan decisions for the decennial census.

I think if you wait that long, you are going to put the decennial

census in one terrible bind in terms of time. In fact, I don't think

the Census Bureau would be able to perform if they couldn't have

decisions on census content until late in 1988 or early 1989.

There is just one other thing on the utility cost data that I'd like

to point out that has perhaps been left unsaid. The survey that

HUD and the Department of Energy are working on is the Residential Energy Consumption Survey, a total of 5,000 households in

the United States, about 1,700 renters, of which about half are in

scope of the HUD definitions used for their fair market rent program.

In other words, 800 to 900 rental properties are going to be studied to try to determine if it is possible, first to develop fair market

rents or gross rents for 2,700 areas used by HUD in that program,

and finally whether those 800 to 900 cases can be used to impute or

model utility costs for each individual household in the Nation.

Chairman ROYBAL. Again I sit here puzzled over OMB's intent, in

view of the fact that there's so much disagreement on the part of

experts. I would like to at least try to understand OMB's position.

In answer to the question of whether or not there would be savings, Mr. Wright's answer was that OMB's proposals will not be

saving Federal dollars. Rather, the intent of the proposals is that

they will be saving our citizens' time. That's in the record as justification for this action.

What do you think of that, Mr. MacRae?

Mr. MACRAE. The answer is there was none of this designed to

save dollars, and

Chairman ROYBAL. Well, isn't the purpose of the Paper Reduction Act to save dollars?
72

Mr. MACRAE. NO.

Chairman ROYBAL. What is the purpose of it?

Mr. MACRAE. The purpose of the Paperwork Reduction Act is to

ensure the burden imposed on the public, the American public

Chairman ROYBAL. But it also saves dollars, does it not in

making things more efficient? .. Mr. MACRAE. It could save dollars in the sense that, first of all,

your time is freed up. You don't have to spend as much time filling

out forms. Obviously, you can use your time in a different fashion,

but that is really not what we had looked at in terms of this whole

exercise or any of our exercises with the paperwork act.

The second thing under the act is the whole question of quality

of data, and the act is very clear on that. We are to ensure that the

data is of the highest quality. Now Mr. Young and others have

raised questions about the actions we've taken here, or that we've

suggested be done first and be tested, but I will come back to the

point that we do believe the things we have raised should be tested.

We are hoping that they will be tested, and we will have some results in a timely fashion. How much time the Census Bureau has

or needs, I can't answer. They should actually respond to that.

We stand ready to move and analyze whatever information and

data we can have made available to us. We also expect Congress to

make its views known, as the act intends•that the Congress is repeatedly and constantly kept up to date.

Chairman ROYBAL. All right, Mr. MacRae, I'd like to ask you this

question. Once you complete your so-called dress rehearsal, and

pending the receipt of the results from the dress rehearsal, will

OMB then be in a position to recommend to the Census Bureau

that it should continue to plan for the possibility that a full census

will be conducted with a sample of 16 million housing units and all

of the housing questions on the 100 percent form?

Mr. MACRAE. We will respond to a request from the Census

Bureau for clearance of the final form and content and so forth

whenever it is submitted to us. They have to come back with the

final form. They have to submit the final form to OMB for clearance. We will respond in a timely fashion. In fact, we must. We

can't take anymore time than 90 days to review the form. The

clock starts when they submit the final census form, and it's a 90

day clock, and we have to respond.

Chairman ROYBAL. Supposing then that the recommendation

would be that you go to a larger size. Would you then do that?

Mr. MACRAE. We will look at all the information we have available at that time and make an assessment, and if the assessment is

that that is in fact warranted and we should do it, then we will

Chairman ROYBAL. All right. Before you do all of this then, you

will definitely examine all possibilities. In other words, you're telling the committee that there is a possibility that when you conduct

this dress rehearsal that you might change to the larger form?

Mr. MACRAE. TO a larger census size? Absolutely. We're not foreclosing that. The dress rehearsal was one approach, and we said

let's assume it's a 10 million sample size.

Chairman ROYBAL. It seems to me that the testimony presented

before the committee this morning is clearly on the other side.
73

They do not agree with the smaller sample. So that message then

has been delivered.

Mr. MACRAE. We have certainly heard that.

Chairman ROYBAL. NOW the question is, will OMB consider, I

would use this term, the advice that's been given OMB by experts

in the field?

Mr. MACRAE. Yes, sir.

Chairman ROYBAL. SO the possibility is that, in considering these

options, you may in fact conduct the sampling as indicated by the

other members of the panel?

Mr. MACRAE. There is certainly that possibility, and we will give

the statements from the experts here and statements we receive

from other experts consideration.

Chairman ROYBAL. What we're going to try to do, Mr. MacRae, is

to get in a condensed form the position taken by Mr. Young, Mayor

Holland, Ms. Turner and Ms. Becker and then submit it to OMB as

the position taken by this committee. After that is done, we would

like to have you tear it apart and tell the members of this committee why we are wrong or, if you happen to agree, also tell us that.

Will that be satisfactory?

Mr. MACRAE. We will certainly comply with it, sir. The only

thing I would ask is, it may take a couple of days to respond in

that fashion, and we would ask a reasonable amount of time to respond. I don't know if you want to extend the time for keeping the

record open, as a result.

Chairman ROYBAL. Well, we would like to, first of all, have you

know what the position of the committee is, and I think you can

well guess what it is now.

Mr. MACRAE. Yes, sir.

Chairman ROYBAL. And then look at the entire situation from

the standpoint of OMB's entrance into this matter, and how OMB

can do the best job possible. I'm sure you're interested in that.

Mr. MACRAE. Absolutely.

Chairman ROYBAL. And it could very well be that what you have

been proposing is your temporary position and that you may be

changing your strategy in the days to come.

On the other hand, that may not be the case at all. What I'd like

to do is summarize our position, hand it over to you, and then tell

us what your position is.

Mr. MACRAE. We will respond, sir.

Chairman ROYBAL. What I would like to do now is ask anyone

else on the panel if they wish to make a closing statement.

In view of the fact that no one has indicated that a closing statement is to be made, I'd like to thank the members of the panel for

a very interesting discussion. I want to be sure to let you know

that I've learned a great deal. I'm not an expert in this field. In

83-794 0-88-4
74

fact, I've never been involved in the matter of census and all these

fancy phrases that I heard today. I learned a great deal, but I sincerely hope that the end result is that fairness will be applied and

that whatever is done takes into consideration the best interests of

the people that are involved, not the reduction of paperwork and

all these other things that sometimes we deal with, forgetting the

fact that the people will suffer the consequence of our inability to

get the information we want.

May I thank each and every one of you for your presence this

morning. The hearing is adjourned.

[Whereupon, at 11:32 a.m., the hearing was adjourned.]
APPENDIX

EXECUTIVE OFFICE OF THE PRESOENT

omct or MAMAOIMCMT AI« Buoorr

SEP I 6 B57

Honorable Xatharlna N. Bulew

Assistant Sacretary for Adalnistratlon

Oapartaant of Coaaarca

Washington, D.C. 20330

Oaar Xayt

Oh Juna 37, 1917, tha Buraau of the Cansus subaittad its dress

rahaarsal for tha 1990 cansus to tha Office of Kanagaaant end

Budget (OHB) for review under the Paperwork Reduction Act of

1910. As Z inforaed the Departaent en Tuesday, Septaaber 35,

19•?, ve have concluded our review end ere unable to epprove the

proposed dreas rehearsal, es subaittad. X have discussed eur

concerns with Departaantal officials, and appreciate their

cooperation with eur Paperwork Reduction Act review. This letter

is to elaborate upon eur discussion.

Under the Paperwork Reduction Act (the Act), Federal agencies

that propose to collect statistical and other inforaation ere

required to subait their proposals to 0MB and to deaonstrata to

OHB end the public that the utility of each question and the

needs to which it responds justify the cost and burden involved.

OMB is required to review and either approve or disapprove each

proposal baaed on criteria sat forth in the Act. Specificelly,

before approving any collection of inforaation, OMB is required

to deteraine that the inforaatidn has practical utility and that-'

the collecting egency has reduced "to the extent precticable and

appropriate the burden on peraons who will provide the

inforaation.1*

The Paperwork Reduction Act else aakas OMB responsible for

esteblishlng and evarseaing standarda for Federal etatistical

prograaa, in order to aalntain and iaprova the quality of

government statistics. OMB's inforaation collection reviews for

statistical surveys such as the decennial censue focus not only

on burden but elso on quality issues. Regarding general purpoaa

statistics, practical utility is defined es the actual, not the

theoretical or potential, usefulness of inforaation to agencies

and the public, taking into account ite accuracy, adequacy, and

reliability, and the egency's ability to process the inforaation

in a useful and tiaely fashion.

(75)
76

Our r«vl«w of th* propotmi drao r«h«»r«»l includad nuaaroua

dl»cu«iion» with C«n»u» Bureau staff and • caraful analyela of

»atariaX aubnlttad by th* Bureau and eoaaants to our public

docXat. For.th* raaaona Indicatad balow, and In accordanca with

th* Act and S CFR 1)20.13, va ara disapproving th* 'proposal as

subailttad by th* C*nsus Bursau. Th* quaatlonnaira* and saapllng

design subalttad for raviaw do not B**t th* critarla of practical

utility and •iniaication of burdan astablishad by tha-Act.

However, v* believe that Census can Improve th* proposed dress

rehearsal so that it aeets th* criteria of th* Act. OKB la well

aware ef the schedule th* Census Bursau aust »eet in order to

conduct a useful dress rehearsal and a successful census in 1990,

and urges the Bureau to consider our proposed changes

axpedltiously. Upon resubnisslon of a aodlfiad proposal, OKB

will conduct its raviaw quickly, while providing an adequate

opportunity tor public cownent.

Below, we describe in detail the reasons for our action and bow

th* dress rehearsal can b* aodifi*d to B**t th* standards of the

Act.

Background

Th* Bureau •stlaates that the 1990 census will cost $3.< billion

to carry out and will iapose a paperwork burdan ef approxlaately

32 Billion hours en respondents. These levels ef public

•xpsndltur* and burden alone Bean that the 1990 census Bust Best

a high standard for both quality and utility. But Bora

iBportant, the 1990 census Bust b* abl* to aset its basic

Constitutionally-required purpose ef counting th* population ef

the Nation. These fundaaental data ar* necessary to apportion

congressional districts aaong th* States and ar* also used to

dotarain* th* allocation ef billions ef Federal dollars. If the

Census Buresu does not accurately count the population,

congressional repressntatlon aay be inaccurate and Fadaral

dollars aay be inequitably distributed.

Any effort to ensure an accurate count aust addrsss the risk that

people will not aall in or answsr correctly a questionnaire that

they consider too long or that contains questions that they

consider intrusive or inappropriate. During the 1980 census, the

Bursau experienced significant difficulties in getting complete

and accurate responss. Court casss are still pending, in fact,

that contest the Census Bureau's count. He believe that Census

aust taka significant steps to iaprovs response rates and th*

quality ef the data collected.

Th* Census Bursau has propossd a "short" fora that consists ef It

questions (7 questions on each individual in the household snd 10

housing questions) that ar* to b* answered by each household in

th* United States. The "long" fora, with 44 additional questions

and aany additional subparts, is to bs sent to a sample of 1 in •

households. The questionnaires are first asiled to each
77

r««pon(J«nt. A r«apen>« rat* of •bout ?• paremt is Mcpaetad.

Census Burasu SBpleysss In th* field than call or visit tha

liousaholds that did not return their fonts in an atteapt to

collect infonation on everyone in the country.

The fona that are returned are then cheeked to identify thoae

that are filled out Incorrectly or incoapletely. The Bureau vili

first try to call respondents to correct the errors -discoveredt

if this fails, an anuBarator aay visit tha respondent,"

Zn tha 1980 census, about 30 percent of the short fonts and 45

percent of the long fons "failed edit," and required follow-up.

These figures appear to understate the actual proportion of

questionnaires with errors, since accuracy atandarda had to be

relaxed to penult tha existing workforce to handle the large

nuaber of errors.

Kesponse Kataa

In 1975, Congreae inserted Into Title 13 of the United States

Coda (the Census Code) a new section (Section 19S) Bpecifically

authorising tha Census Bureau to uaa statistical aaapling

whenever feasible in all areas of the census except the actual

population count. This action recognized developnents that bad

already taken place within the Census Bureau. Ironically, since

this statute was passed, the statiatical portions of the census

design have not taken advantage of the potential for laprovaaent

in •tatlstical design offered by the statute. Tha 1970 design

used three different forms, each with a different length and

aaapllng rate. In 19B0, two forms were uaed, but the saapling

rat* for the long for* was varied to aateh the population

densities of the areas surveyed. For 1990, the Bureau has

proposed a single long foza, ualng a saaple with a constant rate

of 1 in 6 households.

During the sane period, response rates have steadily declined.

Zn 1970, the response to Bailed questionnaires was SI percent forth* short fora and S3 percent for the long and very long fonts

coabined. In 1980, the sail response for the short for* dropped

to S2 percent. The Bureau has recently projected a sail response

rat* of 78 percent for 1990. We are concerned about this trend.

There is SOBS indication froa recent ressarch that tha public is

•or* concerned about privacy, less sanguine about surveys, and

aor* suspicious of •govemaent than It waa In 1970. But In Ita

propoaed dreas rehearsal tha Bureeu hea not reduced the burden or

the number of sensitiv* questions as a aeans of laproving

response.

We believe thet the length of the questionnaires and the

sensitivity of some questions aay contribute to respondsnt

resistance. Soae research has Indicated that a questionnaire

•iailar to the one under review waa found to be ooaplicated and

•ovarvhelaing" by respondents, while an alternative waa described

as alapla and "easy to answer." It baa also shown that soae
78

•inorlty group* v«r« offandad by quastlons th«y considarad an

•invasion of privacy* and unralatad to a "population count."

Many of thaaa individuals could saa no rationala for tha

asrtranaous quastions unlass tha answars wara to ba tumad ovar to

valfara agancias or ethar authoritias, and thus aco£fad at

assurancas of confidantiality. (Saa Rafarancas 1, 2, 1, and 4.)

This raaaarch strongly suggasts that counting tha population in

larga citiaa ia coapllcatad by auspicions angandarad by quaationa

not ralatad to tha population count.

Anethar conaaquanoa of high rataa ef nonrasponsa and adit failura

is tha anoraous worXforca ef anuaaratora raquirad to viait

•illiona of household* and collact inforsation in paraon. For

tha 1990 cansus, tha Buraau astiaataa that evar 300,000

anuaarators will ba naadad. Tha cost ef such a workforce Mkaa

up • large part ef tha budget for the census. The probleas of

adequately training end managing such e uorkforce ere

significant. Taking eteps to increaae the response rate for the

censue would reduce the nuaber ef enuaarators needed and allow

those eaployed to foeue aore on counting end collecting data en

tboea qroupe traditionally the aost difficult to enuaerate.

The basic strategy underlying e aail-out census is sound•it is

beat to let the population enuaarate itself es auch as possible.

Soae respondent errors are inevitable, but the cenaus short fora

aust bo es siaple end es inoffensive es possible to alniaite

error. Xt le iaportant to reaaabar that the priaary purpose of

the census Is to provide en eecurate count ef the population of

the Nation.

The decennlel census also provides a unique opportunity for a

lerqa saaple study to provide reliable estiaataa of population

eheractariatica that ere uaad by many program* at ell levele of

governaent. These data ere used by public officials end by both

public end private resaarchars. Xt is iaportant for thaaa data

to be accurate in order to have practical utility. Xt is else

iaportant that the eaaple sice and design do not coaproaise the •

priaary objective ef the census•obtaining en eecurate population

count.

laprovaaants to be Made

Xn order to assure a successful 1990 census, the Census Bureau

ahould aake a number of changes aimed at iaproving response.

Although there ere aany such possibilitiea for iaproving the

content end design, we believe Census should focus on three areas

where substantial iaprovaaants can be aade in tiae for e

realiatic drasa rehearsal in 1988.
79

1. JUX Btlacfd housing qu»»tlen« cnlv en th» long fftrx.

Vm b«li«v« 7 of th* 10 housing qu**tlon« preposad should bo ssXod

only en ths long for*. Thsss qusstiens sro ths following:

83: Bow asny rooas do you hsvs in this houss or spsrtaant? Do

MOT count hsthrooBs, porchss, bslconiss, foysrs, balls, or

bsIf-rooas.

H4: Do you havs coaplote plumbing facllitlas in this houss or

•partasntt that is, 1) hot and cold plpad vatar, 3} • flush

tollat, and 3) a bathtub or ahowarT

H5: Is this house or apartaant part of • cendoainlua?

Beat Is this house en ten or aore acres?

b: Zs there a business (such as a store or barber shop) or a

.' . jaedieal office en this property?

B7» Do you have a telephone in this house or epartaent?

Hf: Ansvsr only if you OHM DM AMI BUYING this house or

epartaent~

Nhat is the value of this propertyi that is, how aueh do you

thinX this houss and lot or condoalniua unit would sell for

if it were for aale?

BlOai Answsr only if you PAY XZMT for this houss or apartaant•

Nhat is the aonthly rent?

bi Does the aonthly rent include any aeals?

In addition, the telephone nuaber itself (B7) should be asXed en

the bseX of the long or abort fora.

The long fora saaple will generally be adequate to aeet ths

accuracy requlreaenta for thess data. Ths Departaent of Bousing

and Drban Davelopaant coaaanted en such s aodifieation in

correspondanee to our public docXet, indicating that the

Departaent does not need these questions ssXed of 100 percent of

households for purpesee of Fedaral housing programs,

rurtharaore, we have received coaaants in our public docXst

describing needs for thsss data; however, aost eoaaanters

expressed concern about outright delation of thess itsas froa the

census. Bassd on thess descriptions of ussr needs, we do not

object to retaining these questions on the long fora.

Undoubtedly there ere date users who would like to retain thess

questions en the short fora in order to collect data froa 100

percent of households. However, careful sampling method* should

alleviate aost of these ussr concerns. In order to sssurs that

the 1990 census fulfills its primary function of enuaeratlng the

population, it is necessary to balancs some user requests against

the potential improvement in response for ths short fora.
80

This ld«a la net a naw ena. Tha Ganaral Accounting otfiea (GXO)

baa rapaatadly auggaatad ranoving houaing quaationa from tha

ahert form. In a May 1986 raport feeualng en tha ahert ton, tha

cxo eencludad that tha 1990 ahert fen:

ahould ba shertar and aiaplar than tha 1990 ahert fen....

Tha dacannial ahert fen quaatienalra ahould ba United to

tha baaic population and houaing quaationa naadad-te obtain

an accurata population count. Tha 1990 abort 'form centalnad

houaahold quaationa axtranaoua to tha population count.

(Rafaranoa 9, p. X)

CAO found that naada for houaing data fron 100 parcant of tha

houaaholda ahava not bean fully aubatantlatad and avaluatad

bafora balng Included en tha Canaua quaatlonnalra," and that,

furtharaera, tha Buraau had davalopad little Infonatlon en tha

raapondant burdan and tha literacy akllla raqulrad to coaplata

the quaatlonnalre. (Xafaranca 9, p. 35) Tha raport further

•tetedi

that tha houaing quaationa Incraaaa tha eeaplaxlty ef

tha quaatlonnalra end tend to dlacouraga raaponaa. Zn

addition, a shorter form aay prevlda tha Bureau with

eoat>aavlng optlona for Ita data autoaatlen daclalena.

Zn our opinion, the Suraau la slaalng • chance to sand a

aora uaar-frlandly, and eaalar-to-coaplata fen to O.S.

houaaholda which aay Incraaaa tha aall back rate.

(Rafarance s, p. 36)

I. Zaprova tha aaaela daalan for the lone fen.

The short fen will be sent to 100 percent ef the Nation's

bousahelda, and Is aost laportant for tha Conatltutlonallyrequired anuaaration. Tha long fora, proposed by tha Buraau to

go to a aaapla ef 1 In C (or a total ef 1* •llllon) houaaholda,

eontalna a graatar array ef quaationa. Including ones that

raspondanta nay conaidar aora aanaltlva than thoaa en tha ahert

fora. Wa have concerns about tha burdan lapoaad by and accuracy

ef tha data that are cellectad en tha long fen, and ballava that

the raaponaa rate can ba laprovad and tha burden en raapondanta

raducad algnlfIcantly. Such changaa can be iaplaaanted, in part,

by changing tha saapllng daalan from the propeaed saapla ef 1 in

C houaaholda. Wa dlacuasad with Canaua staff, for exaapla, a

alapla aatrlx saapla daalgn which had tha potential to reduce

burdan, Incraaaa raaponaa rate, and iaprove atatlatlcal

reliability. Given tlae constraint*, however, we do not believe

such a change can be developed In tlae for uae in the dreaa

rehearaal.

There are other saapla deaigna that we believe will reduce the

nonreaponaa and the error ratea exparlenced in 1990. (For

exanple, sea Reference «.) The Bureau should consider, for

exaapla, s variable rate saapla, which would reduce the overall
81

feurdtn of th« long fen «nd thus h«lp r«duc* th« nusbcr of

nonr«spons«s and •dit failures, in the p*st, this has bsan dona;

saspling rates have been varied in rural, suburban, and urban

areas. This' approach persita a high saspllng rate to be used in

less densely populated araaa vhare it is needed, with ji such

lover rate for aore highly populated areas where densities are

typically 500 tiaas greater. A sanpling rate as low as 1 in 20

would provide preciae estimates down to the level of individual

blocks in central cities. Such a sanpling rate in urban areas

would also assure that 95 percent of these hard-to-count

households would receive the siaple, nonsensitive short form.

This approach should reduce nonresponse and response errors in

urban areas where they have been aost significant.

3. Delete aavaral questions.

Aaong the 44 additional questions included en the long font are

questions that produce batter data than others. That is, for

•eae questions, errors in response are substantial. Zt has been

found, for exaaple, that aany people answer Incorrectly questions

about how auch their utility bills have been, the Departaent of

Energy's Energy Znforaatien Adainistration realised this seae

tlae ago and now conducts a different type of survey to collect

more accurate data en energy costs. People say consider ether

questions sensitive and aay either refuse to answer or give

inaccurate responses•the questions en rent and Incoae, for

exaaple. In these cases and ethers like thea, such response

error aay dwarf saapling error. Thus, only incrsased costs and

inaccurate data are gained by a large saaple of heavily biased

responses.

With this in aind, we suggest that Census delete froa the long

fora questions H16, B17, and Bit. Census test results reported

In 1979 showed that utility cost questions, In particular,

produced responsss that ware exaggerated by about SO percent.

(See References 7 and •.) These results eaae toe late to reaove

the questions frea the 1910 Census. The 1996 Rational Content

Test showed that rewording the utility cost question reduced the

bias by only 10 percentage points. Since the census fora was

slready toe long to assure reasonable error rates, inclusion en

the 1990 Census of the biased utility questions aeant that

iaportant questions en health insurance recoaaended by the

Federal Agency Council had to be dropped.

There is no aagic number of appropriate census questions that

should be ssked on the long or short fonts, but each additional

question raises the risk of nonresponse and errors. The Census

Bureau's working principle in constructing the proposed

questionnaires was to keep the length approxiaatcly the same as

the 1980 Census. More work should be done to ensure that the

response and error rates are better than in 1980. This can be

done for the short fora by reaovlng questions, and leaving then

only in the long fora. Tor the long fora, considering responss
•rror •• wall •• randea error provldas • aor« usaful erltarlen

for d«t«n>inlng eontant, and will claarly alialnata aeaa

quaatiena trea thia langthy quaationnaira.

yaaolution of Froblaaa

In racant aaatlnga with efficiala and aanler ataff of tha

Dapartaant ef Ceaaarea and Canaua Buraau, wa diaeuaaad tha

problaaa and auggaatad aodifieationa dascrlbad abova. Wa ballava

that thaaa problaaa can ba raaolvad quickly and that tha draaa

rahaaraal can procaad without dalay. Our auggaatad aodifieationa

to bring tha draaa rahaaraal into conforaanea with tha principlaa

ef tha Paparwork Raduction Act ara auaaariaad balowi

1) Quaationa R3, B4( B5, 116, R7j H9, and BIO should ba raaovad

froa tha short fora but ratainad on tha long fora, providad

that a block for a contact talaphona nuabar la placad on tha

' back covar ef both short and long forma in llau of tha heaa

talaphona nuabar raquaatad In quaation B7.

2) a) Tha propoaad saapllng fraction of 1 in « ean ba

aaintainad for tha laaat populated canaua tracts, but ean ba

raducad to produca saaplas of approxiaataly tha saaa sisa and

praeiaion for acre haavily populated eanaua tracts.

b) Altamativaly, tha saapling fraction say ba varied

further to iaprove efficiency with a aaxiaua saapling rate not

exceeding 1 in 3 for any jurladiction or eanaua tract and with

a national saaple site that does net exceed 10 Billion

houaeholda.

S) Quaationa Hi«, B17, and Bl* should be reaoved froa the long

fora.

Xeviaed questionnaires and aaapling specificetions for the three

Dresa Behearaal aitea should be subaitted for review aa aeon aa .

poaaible to perait the dreas rehearaal to go forward en schedule.

OMB will review such a resubaiasion expeditioualy, and will

include in such a review an opportunity for the public to

eoaaent.

We look forward to working with you and your staff in lapreviag

the quality ef the 1990 cenaua.

Sincerely,

Wendy L^Craaa

Adnlatrator for Xnforattion

and Regulatory Affairs

Encloaurea

eei Robert Ortner

John 6. Reane

Ratharine N. Bulow
83

R«f«r«nc«s

i. 1»»8 C«n»ui of T«np«. Tlorida•roeu« Creup•rlnal Moert.

Market Oynanic*, Inc., Subnittad to tha Buraau of tha Cansua

April 17, 19B5. '

2. Final Beport en Keaulta of Four Focua Croupa In gaat Cantral

Miasiaaippl About Raapondinq to tha Canaua. Riva, Inc.,

by Naoai R. Kandaraon and Crag Cay, For tha V.S. Buraau of

tha Cansua, Dacaabar, 1985.

3. Raport on Obaarvatlon of Canaua Focua Croupa Hald bafora tha

1986 Taat Canauaaa. 1986 Tast Canaua•Pralialnary Raaaarcb

and Evaluation Kanorandua No. •. Carolaa Buah, U.S. Buraau

of tha Cansua, May 1, 1966.

4. Outraaeh Focus Croup Raports grog tha 1986 Taat Canaua ef

Cantral Lea Anqalas County. California. 1986 Taat Cansus•

Praliainary Rasaarch and Evaluation Maaorandua Me. 11.

Micbaal E. Fraaaan, 0.8. Buraau of tha Cansus, undatad.

•5. pacannial Cansus--Issuas Ralatad te Ouasttennaira

Davalopnant. Unitad Statas Canaral Accounting Offiea.

CAO/CSO-86-74BR. May 1986.

C. Pacannial Cansus. 1990 Dacannial Cansus•'Daelslon Maaorandua

Ko. 11. Nilllaa P. Butt, U.S. Buraau of tha Canaua, July 17,

19*6.

7. Accuracy of Raporta of Avaraqa Monthly Otility Costs (Oaa and

Elactricity) for Ovnar and Rantar Houaaholda.Rasults

Maaorandua No. 14. 1976 Cansus of Travis County, Taxas.

Patar J. Froncrak, O.B. Buraau of tha Cansus, March 18, 1977.-

8. Accuracy of Raports of Otility Costs for Occupiad Houaaholda.

Results Maaorandua No. 37. 1977 Census of Oakland,

Caiifomia. David A. Koons, O.8. Buraau of tha Cansus, July

30, 1979.
SxS

NOV 2 7 1987

84

UNITED STATES DEPARTMENT OF COMMERCE

Byr«au of tha Census

WaiMgtan. DC 20233

Ornct Of THt WRECTOB

MEK>RANDUH FOR C. Louis Klnctnnon

Deputy Director

Frora:

Subject:

Ch«r1es D. Jones ^jj

Associate Director fir Decennial Census

Implications of the Dress Rehearsal Clearance

This is additional Information about the September 16 letter from the

Office of Management and Budget (OHB) concerning the Census Bureau's June 17

request for clearance 'of questionnaires for the 1988 Dress Rehearsal. I am

forwarding information on the implications of the guidance WB provided for

the design and content of the 1990 census. The content and sample size

reductions OHB has proposed will affect negatively the statistical reliability

and general utility of the census results during the decade of the 1990s.

We believe that variable rate sampling should be used In the dress rehearsal

and 1990 census. We do not agree, however, with the sample size limitation

of 10 million housing units for the census. The decrease In sample size will -

reduce data quality for 85 percent of households, for more than SO percent of

the design areas (governmental units, census tracts, and block numbering

areas), and for population subgroups, such as American Indians, Asians tni

Pacific Islanders, Hlspanlcs, Blacks, end the elderly.

We propose a sample size of approximately 17.8 million housing units for the

1990 census. This sample would Incorporate the following features. (The

coefficients of variations, or CVs, and probabilities discussed here refer to a

10-percent population characteristic. Data for housing characteristics would

have similar relationships although with larger CVs.)

* Variable rate sampling (see Attachment 2).

* Equal CV for each design area. Each design area would have a CV of

about 10 percent (see Attachment 2).

* Maintain or improve the statistical precision of the 1980 census for

60 percent of the housing units and 77 percent of the design areas

(see Attachment 2).

* For large census tracts (2.S00 or more housing units), strike a

compromise between the relatively good precision of the 1980 census

(with a CV of about 7 percent) and the significant Increase In sampling

error over previous censuses (a 15-percent CV) suggested by the sampling

plan received from the OHB. These tracts contain about a third of the

population and comprise 13 percent of the design areas (see Attachment 2).
85

* For each design area, provide a chance of about 2-1n-3 that a sample

estimate will be within 1 percentage point of the actual value. Under

the OHB sampling plan, the chance of this happening would be about

1-1n-2. That is, about half of the areas would have a sample estimate

more than 1 percentage point away from the actual value (see Attachment 2).

* Reduce the estimated average response time per housing unit In the

1990 census by about 13 percent, relative to the comparable figure

before the 1980 census. This reduction Is a result of sample design

change and reduction in content (see Attachment 1).

* Be responsive. In our opinion, to the needs of census data users across

the Nation (see Attachment 3).

I am enclosing four reports with this memorandum. The first of these

sunmarlzes the Census Bureau's reaction to various points conveyed In the

OHB's September 16 letter; It also has a comparison of the estimated response

burden calculations for 1980 and 1990. The second report Is an evaluation of

alternative sampling plans, including the plan proposed by the 0MB, for the

1990 census. The third report Is an assessment of the data quality Implications

of the 0MB sampling plan. The fourth report documents comnents about the content

issues raised in the CHB's Septeiter 16 letter.

Attachments

cc: W. Butz (D1R) J. Thompson

P. Bounpane R. Griffin

P. Heel en H. Woltman

S. Courtland (PP00) S. Hiskura

F. Ruth (CA0) P. Beman

M. McKay (0MS0) R. Brown

J. Briner J. Dinwiddle

P. Schneider (POP) R. Balr

P. Fulton A. Pacz

N, f<clCenney P. Lichtnan-Panzer

A. Young (HOUS) D. Owyer

L. Norry

C. Young

(STS0)

(DPLD)
86

' Attachment 1

Observations Concerning the September 16, 1987 Reply

by the Office of Management and Budget to the Census

Bureau's Initial Request to Clear Questionnaires for

the 1988 Dress Rehearsal

* Sample design and size (summary), p. 1

* Hill return rates, p. 2

* Filled-edlt operations, p. 3

* Population coverage, p. 4

* Response burden, 1980 end 1990, p. 6

Bureau of the Census

October 1987
87

Sample site »nd design

The Office of Mnagement and Budget (0MB) stated that It wants to Improve the

quality of results from the 1990 census. But the proposed reduction in the

size of the sample demonstrable and substantially contradicts this objective.

If adopted, the CMB sample size limitation of 10 million housing units dearly

will decrease the quality of data, especially for numerically small populations

(such as American Indians, Hlspanics, and the elderly), as well as for most

data publication areas and the vast majority of the population.

In response to concerns about respondent burden and dollar cost, the Census

Bureau has reduced the sample sizes In the last three censuses and, as a

result, there have been marginal decreases In precision of the sample estimates. As the sample size dropped, the coefficient of variation on a

10-percent characteristic for tracts of 1,000 to 2,500 housing units, which

contain half of the population, has crept up from 8 percent (1960) to

9 percent (1970) to 10 percent (1980). A much more dramatic Increase In

error would occur for 1990 under the 0HB plan. For example. In census tracts

having 1,000 to 2,500 housing units, a 10-percent coefficient of variation

for 1980 would become 14 percent In 1990, in increase far greater than those

for the last three censuses. In other terns, the sampling error for

1990 data would Increase by 40 percent over the 1980 levels. For larger

census tracts (above 2,500 housing units), the results of the OHB decision

are even more damaging: the error would be double that of the 1980 results.

The detrimental effects on data quality for this one-third of our population

and 13 percent of our design areas would be dramatic.

The OHB plan has considerable appeal with respect to the precision of estimates

for sparsely populated places. It would maintain the 1980 precision levels for

places with fewer than 1,000 Inhabitants, where only 3 percent of our Nation's

population lives. The Census Bureau supports this objective and has Incorporated it Into the alternative 1990 census sampling plan (see Attachment 2).

The OHB letter also suggests that reducing the sample size will reduce

nonsamp>ing error end, thus, the total error In the data. Neither data nor

statistical theory support this contention. For example, some components of

nonsanpllng error associated with sample data are independent of the sample

size and, thus, would not be affected by a reduced (or Increased] sample size.

This can be seen In two ways. First, almost every model used to express the

total error In an estimate produced from a survey, such as the 1990 census

sample, expresses the error as the sum of a sampling error component and two

or more components due to respondent and other errors (such as enumerator

error). These error models clearly demonstrate that the nonsampllng errors

are Independent of the sampling errors. Second, the Census Bureau conducted

an enumerator variance study that Indicated that the level of enumerator error

In the 1970 census data was the same or slightly higher than in 1960. In

1970. the enumerator assignment size was about one-half that In 1960. suggesting that for a fixed number of enumerators, reducing the enumerator follow-up

work load (and. as a result, the sample size) does not necessarily guarantee

a reduction In the enumerator error component.
Hall return rites

The OMB letter contends thit reducing the nunber of households that receive

the sample questionnaire (or long form) would Improve the nail return rate

and reduce the nunber of field enumerators needed to visit nonrespondlng

households. We share the OfB objective of a higher nail return rate, but the

Census Bureau knows from evidence and experience that reducing the number of

units that receive the long form to the OfB Unit of 10 million would have a

trivial effect on the nail return rate.

There has been relatively little difference between the nail return rates

of census short-form and long-form recipients In an actual census. In the

1980 census, the overall nail return rate for short-forms was only

1.5 percentage points higher than that for long-forms. The OHB points out

that the nail return rates are lower among selected population subgroups

residing In netropolltan areas. Even in these areas, however, there It

little difference between the rates by type of forn. In 1980, the shortform nail return rate for large netropolltan areas was 2.5 percentage points

higher than the long-form rate. In son* of our test censuses, we have

observed wider differences between the nail return rates of shart-forn and

long-form respondents, but these test census results art not supported by

actual census results.

Based on this experience, the Census Bureau concludes that reducing the sample

size would have a trivial effect on the overall anil return rate in 1990.

Applying the 1980 nail return rates by forn type to the sanple design proposed

by the 0MB for 1990, the Census Bureau estimates an increase in the overall

nail return rate of 0.1 of 1 percent for the 1990 questionnaires. The estimated effect is so snll that there would be no reduction in the nunber of

enunerators needed in 1990.

In a similar vein, the On decision to rtduc* the iwab«r of questions on th*

dress rehearsal short fore appears to be based on the assuaption that this

would increase the nail return rate for the forn. Our comparison (summarized

above) of long and short forns that have much greater differences In their

relative length than 0MB proposes for the 1990 fores suggests that the nail

return rates are almost unrelated to the length and content of the questionnaires. The 0HB assumption is at best speculat1ve--clear1y not a sound basis

for making radical changes In the content of the decennial census.
89

Failed-edlt operations

While It Is true (is stated In the 0KB letter) that some 20 percent of short

forms and 45 percent of long forns "failed edit" In 1980, most of these did

not require field follow-up by enumerators. In centralized offices, the

failed-edlt operation comprised three separate phases--off1ce edit, office

telephone contact, and enumerator follow-up. In decentralized offices, the

office telephone contact phase was not used In 1980, although enumerators

were allowed to use their personal telephones.

Data from the 1985 test censuses dearly show (Table A) that the large majority

of failed edit questionnaires are completed by office staff using either the

clerical or telephone contact procedures. Also, the Census Bureau experience

demonstrates a greater success at hiring and retaining a temporary staff for

office rather than for field operations. The 0MB letter states that the

Census Bureau will be needing more than 300,000 enumerators In 1990; this Is

Incorrect. This figure Is an estimate of the total peak-period work force

for staffing the regional and district offices, including many jobs other

than enumerators. For 1990, we plan to Implement the office telephone contact

phase of the failed-edit operation for all of our field offices. With this

change, we should reduce the number of enumerators required for the field-work

phase of the failed-edlt operation.

Table A. 198S test censuses: Percent of failed edit

questionnaires completed, by type of operation

(Data based on short forms and 100-percent

component of long forms)

Clerical Field

Site operation Telephone enumerators

Jersey City 51.7 30.9 17.4

Tampa 54.0 32.9 13.1

The field-work phase of the failed-edlt operation Is conducted after nonresponse

follow-up operations and constitutes a far smaller workload. In addition,

the failed-edlt operation is conducted simultaneously with the vacant-delete

and residual nonresponse operations, so that the vast majority of enumerators

would be needed even If the failed-edlt rate dropped to zero.
90

PopjUtton covtrage

A presumption that the length and content of the census questionnaire affects

coverage (the completeness of population counts) Is t principal rationale for

the OHB's action. The OHB suggests that maximizing the proportion of respondents asked to complete a census short form contributes to coverage Improvement and that, by dropping questions from the short form, coverage of the

population would be Improved even further.

The 0MB based Its arguments largely on results of « few focus groups. Focus

groups can be useful vehicles for Identifying hypotheses that night warrant

testing, but--because of the small number of persons participating in these

Informal discussions, their unrepresentative make ups, and the conditioning

influences upon the members by the discussion leader and the process itself•

they provide no basis for changing a statistical program, much less for

making radical changes in the decennial census.

The Census Bureau finds no statistical evidence to support the QKB contention

of the existence of t relationship between questionnaire length ana coverag*.

In the 1940 census, no forms were handed out, and all data Merc gathered by

enumerators Htio asked the questions and recorded the answers In t book.

Similarly in 1950, fonts were not given to respondents, and enumerators -

recorded replies in a book. The 1960 census Mas the first in which fonts

were handed out to respondents. In two-stage areas (the majority of the

population), short fonts Mere sent to every housing unit. When the short

forms were picked up, if the unit Mas in sample, a long-form questionnaire

Mas administered to the occupants. In the 1970 and 1980 censuses, either a

short font or a long form Has sent to each housing unit In the mail-census

areas. The three earlier censuses (in which long forms Here not distributed)

had worse overall and Black population coverage than the two more recent

censuses, in which respondents knen the content and length of the selfadministered questionnaires (Table B). Because of other procedural differences among these censuses, these results are confounded. They certainly do

not, however, support the OB contention.

Table B. Population coverage of censuses, 1940-1980

(Percent of population covered)

Pc3punnon

Census Total Black

1940 94.4 89.7

1950 95.6 90.4

1960 96.7 91.7

1970 97.1 92.0

1980* 98.6 94.1

• The estimated population included approximately

3 million undocumented residents.
91

The OMB contention and the focus group reports suggest Interesting hypotheses

that should be tested before the year 2000 census. However, the potential

loss in quantity and quality of data for 1990 Is great, without any. evidence

that coverage Improvements will result.
APPENDIX II

"THE 1990 CENSUS AND HOUSING DATA FOR THE ELDERLY:

CAM WE COUNT ON ITT"

Joint Hearing of the

House Select Committee on Aging

and the

Subcommittee on Housing and Consumer Interests

Wednesday, February 24, 1988

Room 311 Cannon HOB

9:30 - 11:30 AH

Hearing Purpoae

The purpose Of the hearing is to examine in greater depth concerns raised at an

October 20, 1987, hearing of the Select Committee on Aging which revealed that the

proposed deletion of several housing and energy-related questions from the short form of

the 1990 decennial census, as well as a substantially reduced sample size for the census

long form, has serious implications for the ability of federal, state and local officials and

the private sector to plan for the housing and service needs of older Americans.

Background Summary

On September 16, 1987, the Office of Management and Budget (OMB) - citing its

authority under the Paperwork Reduction Act - rejected the Census Bureau's proposed

census questionnaires. These questionnaires (known as the Dress Rehearsal) are an

operational dry run of all the features which will be used in the actual 1990 census. The

Dress Rehearsal is scheduled to be tested during the Spring of 1988. In the past, only

marginal adjustments to the actual census have been made after the Dress Rehearsal is

undertaken. (For more detailed information, see enclosed CRS report: "Census Questions

and OMB% Review of the Census Bureau Proposal: A Summary and Brief Analysis").

In general, OMB proposed that the Census Bureau: 1) move virtually all of the

housing questions from the form which goes to all households to the form which goes to a

much smaller sampling of households; 2) reduce the number of households which receive

the long form from 16 million to 10 million; and 3) eliminate completely three housing

questions related to utilities. (See p. 3 for more specific details of census changes).

At an October 20, 1987 hearing of the Select Committee on Aging ("Planning for

an Aging America: the Void in Reliable Data"), testimony from the Census Bureau and

other experts indicated that the proposed changes in the housing questions, as well as the

reductions in the sample size of the census long form, will make it extremely difficult -

if not impossible - for many localities to obtain adequate data suitable for planning for

the housing needs of smaller population subgroups, such as the elderly.

On October 28, 1987, Dr. Wendy Gramm, Administrator for Information and

Regulatory Affairs at OMB, notified the Department of Commerce and the Census

Bureau that the census forms for the Dress Rehearsal are final as OMB" proposed -

virtually all of the housing questions are to be moved from the short to the long form;

the long form sample size is to be reduced from 16 million (one in six households) to 10

million (one in nine households); and two of the utility questions are to be eliminated

completely. Hie third utility question - which is key to determining Fair Market Rents

for a given area - was significantly changed. (Copy of the October 28 letter is attached).

These changes are being implemented by OMB despite an analysis by the Census

Bureau which indicates that there are serious problems associated with the reduction in

sample size for the census long form. (Copy attached).
93

BACKGROUND ON Ojjgg PROPOSED CHAMGES TO 19»0 DECKMNIAL CKNSOS

In a September 16, 1987 letter from the Office of Management and Budget (OMB) to the

Census Bureau, OMB rejected the Census Bureau's questionnaire and sample design for the

1988 Dress Rehearsal. Citing its authority under the Paperwork Reduction Act, OMB provided

to the Census Bureau the following specific changes in the questionnaire and sample design:

0 Delete three housing-related questions from the census long form, including: 1) "What are

the yearly costs of utilities for fuel for this house or apartment?* 2) "What kind of heating

equipment is used for heating water?* and 3) "Which fuel is used for heating water?"

- ImpBeatiops of Deletions;

o With the elimination or proposed alteration of the question on annual utility costs,

there is serious question whether federal, state or local officials will be able to

calculate "gross rent", an item used extensively in housing cost analyses, including the

establishment of Fair Market Rents (FMRs). The FMR is used by the Department of

Housing and Urban Development to determine the amount of income which the elderly

and other low income individuals must pay for subsidized housing.

o OMB will likely argue that they have devised an alternative model for estimating

utility costs, but there is serious doubt whether this model works and how costs for

homeowners and metropolitan areas would be obtained. This change would also

prohibit any cost comparisons between the 1980 and 1990 data so that it would not be

possible to analyze the affect of housing policies during the Reagan administration.

o By taking the utility cost data out of the 1990 Census, it will make comparisons with

the 1980 data impossible, ending long-term trend analyses from previous censuses.

o This further complicates the ablity of policy planners to obtain data which reveal what

percent of a household's income is spent for shelter and how this varies between

income levels, between owners and renters, between the young and the old, and even

between different neighborhoods in the same city.

o The question on heating equipment provides local housing and health officials with

information concerning how much of the housing stock uses outdated or potentially

dangerous heating equipment. This can be a particular problem in rural America

where stoves, fireplaces, and unvented heaters are used.

0 Hove seven of the ten housing questions from the short to the long form, including:

"How many rooms do you have in this house or apartment?"

"Do you have complete plumbing facilities in this house or apartment?"

"Is this house or apartment part of a condominium?"

"Is this house on ten or more acres? is there a business office on this property?"

"Do you have a telephone in this house or apartment?"

"What is the value of this property; ie, how much do you think this house would

sell for if it were for sale?"

"What is the monthly rent?" "Does the monthly rent include any meals?"

- Implications of Proposed Shifting of Questions:

o The overall result of these changes is that, starting in 1990, almost the entire

housing census will no longer be a census, but instead will be a sample survey

producing estimates rather than counts. This means that there will no longer be

housing characteristics data available on a city block by city block basis or for very

small rural areas. Cities and counties could no longer assemble block data into areas

that they need for planning or for grant applications.
94

o The Census Bureau has Just completed a very detailed computer mapping system

which identifies every city block and rural land area in the nation. This system could

not now be utilized to produce rural block housing characteristics data because such

data would not be collected. Thus, just as rural America was about to obtain

statistical equity with urban American, the opportunity would be lost.

o Questions such as: the number of rooms in the unit; whether the monthly rent

includes meals; and whether there is a telephone in the house or apartment are

particularly important in terms of local planning for the needs of the elderly.

o Many of these questions have historically been used to document the locations of

substandard housing. It will now be very difficult, and in some cases impossible, for

local officials to pinpoint exactly in which neighborhoods housing problems for the

elderly are most prevalent.

o Shifts the majority of the housing questions from the short form, which reach 100%

of American households, to the long form, which is proposed to reach only 1 in 9

households. By reducing the sample size which receives these housing questions, it

will not be possible to get detailed, reliable local data on the particular needs of

small population groups such as the elderly.

0 Reduce the sample size of the census long form from the 16 million (one in six households)

which the Census Bureau proposed for 1990 to 10 million (one in nine households), b 1980,

the sample size was 19 million.

- Implications of Reductions in Sample Sze;

o The Census Bureau and local planners will be unable to obtain detailed data on the

income, living arrangements and demographic characteristics of subpopulations of

the elderly and many other vulnerable subgroups because sample sizes will be too

small to yield statistically reliable results.

o The lack of specific local data will be extremely costly for local agencies or the

private sector. Either much larger samplings will have to be run to analyze what

census data are available, or localities will have to implement their own small

surveys. Few local agencies have the resources to undertake detailed surveys. Such

surveys would also lack standardization with other data.

o OMB may argue that the sample size reduction was needed to reduce follow-up and

the need for substitutions. However, procedures used for "allocation of nonresponse"

is less accurate for a small sample than for a larger sample, so this argument is not

statistically valid.

0 Vary sample sizes of the long form: OMB proposed, for example, a higher sampling rate

than the current 1-iii-6 in rural areas, but a much smaller sampling rate, as low as l-in-20,

for urban areas where population densities are much higher.

- Implications of Varying Sample Size by Population Density

o Many of the urban areas which are proposed for reductions in sampling rates have

historically had the lowest overall response rates to the decennial census. Cutting

back on sample sizes in these areas will likely compound the problem of getting

incomplete and inaccurate data.
95

Overview of haues to be Addressed;

0 Although the decennial census is not scheduled to be taken until April 1, 1990, a

major dress rehearsal which tests the census instrument will be held in the Spring of

1988. Historically, the questions, methodology and assumptions used in the dress

rehearsal closely correspond to the content used in the decennial census.

Consequently, if Congress determines that there are problems with the proposed

changes in the census questions and sample size they must be addressed within the

next few months or the quality of the data could be affected until the end of this

century.

0 The hearing will examine how the shifting of virtually all the housing and energyrelated questions from the short form of the 1990 census (which goes to 100% of

the households) to the long form (which would go to less than one of every nine

households), will affect the ability of local officials and planners to obtain

statistically reliable housing data on smaller subgroups of the population, such as

the elderly.

0 More specific information will be obtained concerning what factors were taken into

consideration by OMB with regard to the ability of the Census Bureau, Federal

agencies and local planners to cross-tabulate housing data across smaller subgroups

of age, race, ethnicity, disability status and other subpopulations. OMB imposed

these changes to the dress rehearsal very late in the process - despite an extensive

three year process used by the Census Bureau in developing the questionnaires and,

in some instances, over the objections of federal agencies and local officials which

depend on the quality of the data.

0 One major issue raised at an October 20 hearing of the Aging Committee was the

concern that the proposed reduction in sample size of the census long forms from

16 million (one in six households) to 10 million (less than one in nine households) will

make it extremely difficult, if not impossible, to obtain detailed local data on the

income, living arrangements and demographic characteristics of elderly individuals

because the sample sizes will be too small to yield statistically reliable results.

0 One question OMB proposed to eliminate concerns annual utility costs. This

information is used to calculate "gross rent", an item used extensively in housing

cost analyses, including the establishment of Fair Market Rents (FMRs). The FMR

is used by the Department of Housing and Urban Development to determine the

amount which the elderly and low income individuals pay for subsidized housing.

This not only raises questions about how this information will now be obtained, but

it also brings into question the nature of OMB's decisionmaking process. When were

opinions solicited from other agencies which rely heavily on census data for

planning and policy decisions, and what was the nature of these opinions?

0 Also to be examined are the implications of the proposal to vary the sample size

taken in urban and rural areas. A sampling rate of one in two would be used in

some rural areas, but a much smaller sampling rate, as low as one in twenty would

be used in urban areas where population densities are higher.

0 Despite all these changes which have been proposed, OMB has not argued that they

would save any money for the 1990 census. The proposed budget ($2.6 billion) is the

same as before OMB's changes were proposed.
96

APPENDIX HI

88-42 GOV

^nffwmwi Luium

QUESTIONS AND OKB'S REVIEW OF THE CENSUS BUREAU

PROPOSAL: A SUMMARY AND BRIEF ANALYSIS

Daniel Melnick

Specialist in American National Government

Ccverr.ment Division

and

Alexander Lurie

Senior Research Assistant

Government Division

Updated January 13, 1988

CONGRESSJONAL

RESEARCH

SERVICE
97

ABSTRACT

This updated report of CRS Report 87-812 GOV reviews recent developments

regarding the content and procedures for the 1990 Census including OMB's

scrutiny of the need for information for various subjects.
98

SUMHARY

By law. che Office of Management and Budget (OMB) is required Co approve

every form used by the Federal Government to collect information from the

public. Under this authority it reviews proposed census questionnaires.

The decennial census is the largest single survey conducted by the Federal

Government. As such, its questionnaire receives the highest level of

consideration and scrutiny, including extensive field testing and consultation

with Federal agencies. States and local government s and the public as we11 as

Congress. In the past, the final test [known as the Dress Rehearsal 1 has been

an operat i onal dry run incorporat ing all features of the quest ionnai re and

procedures used in the actual census. Only marginal subsequent adjustments are

envisioned as being necessary after the Dress Rehearsal.

On September 16, 1987, OMB announced that it had decided to reject the

Census Bureau's 1988 proposed Dress Rehearsal questionnaire. At the same time,

OMB asked the Bureau to modify its request and return it for expeditious

handling.

Specifically OMB asked the Bureau to:

move most of che housing questions to the sample form;

reduce the number of households that receive the long form from

16 million to 10 million by adopting a variable sampling rate;

and

eliminate three housing questions related to utilities from Che

form.
99

On October 28, 1987 OMB approved Che Census Bureau's modified Dress Rehearsal

questionnaire that complied with all of OMB's objections except for a

compromise on one ot the utility questions.

This report summarizes the events leading up to this development and Che

outcome and its possible implications.
100

CRS-vii

CONTENTS

ABSTRACT Ui

SUMKARV v

BACKGROUND OF THE DISPUTE 1

OVERLAP BETWEEN THE DRESS REHEARSAL AND THE CENSUS 2

AUTHORITY FOR OMB'S ACTIONS 3

CONGRESSIONAL REVIEW OF CENSUS QUESTIONNAIRE 3

OMB REVIEW OF THE DRESS REHEARSAL QUESTIONNAIRE «

PUBLIC AND CONGRESSIONAL REACTION TO OMB'S CONCERNS 4

IMPLICATIONS OF OMB'S ACTIONS 5

Questions Eliminated 5

Sample Changes 6

Moving Items From The 100 Percent Census To The Sample 8

THE FINAL OMB APPROVED DRESS REHEARSAL QUESTIONNAIRE 8

DETAILED ANALYSIS OF IMPACT ON THE CENSUS QUESTIONNAIRE 9

The Bureau's Proposal 9

APPENDIX 1: CHRONOLOGY OF CONSIDERATION OF THE CONTENT FOR THE 1990

CENSUS 13
101

CENSUS QUESTIONS AND OMB'S REVIEW OF THE CENSUS BUREAU

PROPOSAL: A SUMMARY AND BRIEF ANALYSIS

BACKGROUND OF THE DISPUTE

On June 17, 1987, under the terms of the Paperwork Reduction Act, the

Census Bureau sent OMB its proposal for the questionnaire to be used during the

1988 Dress Rehearsal for the 1990 census. It is expected that whatever

questionnaire is used for this activity will contain most of the questions to

be used during the 1990 census.

The Bureau's proposal was the culmination of a review process that began

in 1983 [see Appendix 1: The Census Chronology] and involved consultation with

Federal agencies, including OMB, and the public.

On July 24, 1987, OMB informed the Census Bureau that it was concerned

about the justification for a substantial number of questions. This expression

of concern has a timing consequence because to meet the Dress Rehearsal

schedule the questionnaire must be sent to the printer by October 16, 1987;

but, OMB approval is required before this can occur.

In July, OMB questioned the need for including about 60 percent of the

housing subjects. It asked why all but one of those it was willing to approve

could not be placed on the sample form. OMB also questioned the need for

collecting information about unemployment, commuting, fertility and mobility.

Proponents of these items cited the losses that would result from

eliminating then. For example, they argued that if unemployment data were not

collected on the decennial, BLS would not be able to report the local area

unemployment rates for many areas smaller than counties.
102

CRS-2

Proponerus of the housing items said that they are widely used by the

housing industry and also form the basis of other statistical series. For

example, they are used to select samples employed to determine the Consumer

Price Index, which is a key indicator used to increase or decrease some

Government benefits and some salaries in the private sector.

OVERLAP BETWEEN THE DRESS REHEARSAL AND THE CENSUS

Shortly after being informed that 0MB was questioning a large number of

subjects, the Census Bureau issued a statement in which it said that although

the review concerned the Dress Rehearsal questionnaire, "(bjoth the OMB and

Census Bureau regard [its] content ... as a preview*' of the questions to be

used in 1990. "Therefore, the questionnaire changes proposed by OMB . * . would

apply to the 1990 census as we11."

While there have been exceptions in the past (most notably, the addition

of the Hispanic identification question in the 1970 census] generally over the

decades all of the questions appearing on the actual census have been included

in the Dress Rehearsal. The questionnaire to be used in the actual census will

be printed during the fall of 1989, allowing minor changes up to the spring of

1989. However, other preparations {including computer programming for the

tabulations] wil1 begin December 1987 making changes increasingly problematic

after then.

On December 22, 1987, Representatives Dymally, Roybal, Matsui, Garcia,

Mfuine, and Bonker wrote to the Director of OMB that they were "concerned about

the potential impact of changes on the census". They asked OMB "not to close

the door on the final plans for the 1990 census samplng and questionnaire until
103

CRS-3

Congress has had a chance to review" the report required to be filed by the

Census Bureau on April 1, 1988.

AUTHORITY FOR OMB1S ACTIONS

OMB's authority to review census questionnaires is long standing. It can

be traced to the Bureau of Efficiency in the 1920's and was first put into law

in the Federal Reports Act of 1942. It is currently contained in the Paperwork

Reduction Act of 1980, which was reauthorized as a part of the Continuing

Appropriations Resolutions enacted October 18 and 30, 1986 (P.L. 99-500 and

P.L. 99-591; 100 Stat. 3341•p. 335 et seq.). Under this Act, agencies which

use questionnaires to request informat ion from the public are required to

obtain prior approval from OMB. This provision is administered by OMB's Office

of Information and Regulatory Affairs [OIRA.]

OMB officials argue that the Paperwork Reduction Act provides a

congressional mandate to reduce the public's burden in responding to the census

and that in order to fulfill this congressional mandate, OIRA is required to

consider reducing the number of questions on the census form. They contend

that the 1ower than expected public response to the mail census during the

pre-tests indicates that the form is too long and cumbersome.

CONGRESSIONAL REVIEW OF CENSUS QUESTIONNAIRE

Additionally, the Census questionnaire is subject to the congressional

review procedures established in Title 13. Under 13 USC 141, the Secretary of

Commerce is required to inform Congress about the proposed subjects to be

included on the census form by April 1, 1987 and the proposed questions by

April 1| 1988. The first report relating to the subjects was filed with both
104

che House Census Subcommiicee and Che Senate Federal Services Subconuniccee on

March 27, 1967. These subcomiccees held a joinc hearing on Hay 14, 1987,

which was followed by an additional House hearing on May 19, 1987.

Ac cheae hearings Che Census Bureau was asked Co explain che reasons for

including each subjecc on che census questionnaire. Of interest, in terms of

subsequent 0MB concerns abouC housing quescions on che census form, is that che

subcommittees inviced che Department of Housing and Urban Development co

cescify on che housing items, buc ic declined.

OMB REVIEW OF THE DRESS REHEARSAL QUESTIOMHAIRE

The Bureau submitted ics proposal for che Dress Rehearsal questionnaire on

June 17, 1987. OMB raised concerns abouc approving che form on July 24, 1987.

PUBLIC AND CONGRESSIONAL REACTION TO OMB'S COWCERMS

On Augusc 7, 1987, che Joinc Economic Committee (JEC) held a hearing Co

review che implications of OHB's possible accions. Ac that hearing, Or. Wendy

Cramn, Administrator of che OMB's Office of Information and Regulacory Affairs,

was closely quescioned abouc OMB's concerns abouc che census questionnaire.

Dr. Cramn replied thac OMB had not made any final determination abouc Che

questionnaire buc was carefully considering various courses of accion including

alcering che questionnaire and changing che sampling plan.

Subsequenc Co che hearing, OMB received acre Chan 600 leCCers relacing Co

Che proposed changes. On Augusc 25, 1987 ic issued a nocice in che Federal

Rettiscer seccing forch che grounds that ic would use Co make ics decision. OMB

said iC was considering che need for including a wide range of subjeccs on che

decennial census. Ic asked if users knew of alcernacive available information
105

CRS-5

chat was either more accurate than census data or could be used as a

substitute. It raised the possibility that legitimate users could be

satisfied if an alternative and reduced sampling scheme were used to collect

most of the information originally planned for the census. As well, it

reported OMB was considering using alternative government samples or moving

items from the 1001 form to the sample. It stressed the requirement to limit

the public * s burden in responding to the census form.

IMPLICATIONS OF OMB'S ACTIONS

On September 16, 1987, OMB sent a letter to the Department of Commerce in

which it detailed the steps the Census Bureau would be required to take before

approval could be granted.

Questions Eliminated

Generally OMB pulled back from any plan to cut large numbers of subjects

from the census form. Instead, it made marginal changes in Che content but

emphasized reductions both in the short form and the number of people who

receive the long form. OMB's actions can be seen as a response to the public

reaction following the JCC hearing in August.

In an attempt at blunting any further criticism, the Commerce Department's

reply to OMB's letter said, "The public will have ample opportunity to comment

on changes you have directed in content before we submit a final questionnaire

to Congress on April 1, 1988."

Review of the "Dress Rehearsal" for the 1990 Census of Population and

Housing; Notice. Federal Register, Part IV, August 25, 1987: 32114-32118.

83-79A 0
106

This is of incerest because it differs from the position taken by the

Census Bureau and 0MB in July when they said that very few changes could be

made after the Dress Rehearsal.

The three questions slated for elimination relate to energy use and cost.

The most important of these asks for the cost of utilities. This question is

required to calculate total housing costs. Its elimination would make it more

difficult to ascertain regional biases based on differences in weather. The

Department of Housing and Urban Development appealed to OMB for the inclusion

of this item because it believed that eliminating it would make it difficult to

produce accurate estimates of fair market rents as required by the Federal

Housing Act of 1937 as amended.

Sample Changes

OMB's instructions leave the sample design to the Census Bureau but limit

the total sample to 10 million households rather than the 16 million proposed.

They also require that no jurisdiction or census tract have a sampling rate of

greater than 501 and sampling rates be lower in high density population areas

to improve efficiency. Census Bureau analyses show that to comply with OMB's

guidelines for the 1988 Dress Rehearsal, the following sample rates will be

used: a sample rate of 1 out of 2 housing units (HUs•a house, apartment,

group of rooms, or a single room occupied as a separate living quarter or if

vacant, it can be used as a living quarter) in governmental units (GUs•any

incorporated place that has previously received some type of revenue sharing)

with fewer than 1000 inhabitants; 1 in 6 for GUs having populations between

1000 and 2300 and for census tracts and block numbering areas (BNAs•zones that

are specified for the purpose of grouping blocks where census tracts have not
107

CRS-7

been defined) with between 1 and 1000 HUs; 1 in 10 for census tracts and BNAs

with between 1,000 and 2,500 HUs; and, a 1 in 20 rate for census tracts and

BNAs with 2,500 or more HUs.

However, Census Bureau officials believe that data quality will suffer

under OMB's restrictions, particularly as it relates to minority groups. On

December 10, 1987 the Bureau issued a proposal for the 1990 Census calling for

an overall 1 in 6 sample, with the succeeding variable sample rates; 2 in 3 for

GUs with fewer than 1000 persons, 1 in 3 for GUs having between 1000 and 2300

persons and for census tracts and BNAs with fewer than 1000 HUs, 1 in 6 for

census tracts and BNAs having between 1000 and 2S00 HUs, 1 in 10 for census

tracts and BNAs between 2500 and 3500 HUs, and 1 in 12 for census tracts and

BNAs with 3500 cr more HUs.

Those interested in data for rural areas have welcorned the increased

sample for them, but city officials are concerned that the new sampling

procedure will provide them with less information. 0MB says that the reduced

central city sample will free resources that are needed to improve the

accuracy of the central city population count.

One problem will be that limiting the sample size will make it difficult

to provide data that do not coincide with census tracts. For example, it will

make it more difficult to tabulate the number of children in poverty by school

districts as required by the Elementary and Secondary Education Act.

Opponents also contend that operational considerations might make this

procedure difficult to implement. They say that if local census offices were

required to manage several sampling rates, it could add confusion to an already

complicated process.
108

CRS-B

Moving Items From The 100 Percent. Census To The Sample

By moving items from the form received by all of the households to those

received by a sample, the Administration has reduced the detailed data that

will be available. This will limit the statistics available about:

• small towns, rural areas, city neighborhoods, and voting

precincts; as well as

small groups in the population•such as families In

Baltimore headed by Hispanic women with five children.

For example, because the rent questions will now be on the sample form, it will

be harder to estimate the rent paid by households in small areas and rare

groups according to the size of their living quarters.

THE FINAL OHB APPROVED DRESS REHEARSAL QUESTIOtfflAIRE

The final Dress Rehearsal questionnaire reflects almost all of OMB's

objections to the Census Bureau's proposal. First, the Bureau shifted all

questions in point from the 100 percent census to the sample. Second, the

Bureau will use OMB's request of a 1 in 10 (total sample of 10 million) as

variable sample as opposed to a 1 in 6 (total sample of 16 million) variable

sample. Finally, the Bureau will eliminate all three utility questions but a

question on whether or not utilities are included in the rent will be added to

the rent question on the sample.

The Census Bureau continues to argue for the 1 in 6 sample for the 1990

Census. In a report sent to Dorothy Telia, Chief Statistician of the Office of

Management and Budget, on December 10, 1987, the Census Bureau outlines a

series of arguments on why census data quality will suffer from the OMB

requested 1 in 10 sample for the 1990 Census.
109

CRS-9

DETAILED ANALYSIS OF IMPACT ON THE CENSUS QUESTIONNAIRE

The following paragraphs provide a detailed list of the subjects

originally considered for inclusion on the Census questionnaire together with a

review of the impact of the OMB action. Beginning with the items included in

the Census Bureau's proposal of April 1, 1987, we indicate those that will be

retained, moved, or eliminated in accordance with OKB's views.

The Bureau's Proposal

A. 100Z population questions are asked about each person included in

every household in the Nation as well as persons not living in

households. Six subjects are proposed in this category. All of

these were included in the 1980 census:

1. Name; The name of each person will be included on the form but

generally not captured in the computerized record. The main

purpose of this item is to help keep track of who is being

included in the household. It also makes it possible to check

the count during follow-up activities and the evaluation. NOT

CHANGED

2. Household relationship: Respondents are asked to provide the

relationship between the first person listed (generally

themselves) and the other people living in the household. This

information is used to keep track of the people being counted

and is also the basis for analyses that show the condition of

families. Because the census form includes all of the people

living in a household•even if they are not related•this item

is the only way of providing information about families. NOT

CHANGED

3. Sex: This item is also considered to be an important part of

the identity of persons. It is used in many census analyses.

NOT CHANGED

4. Race: The Bureau largely relies upon respondents Co identify

their race (including white, black, American Indian and several

Asian nationalities) and those of the persons living, in the

household. Enumerators are instructed to accept the information

as provided by respondents. This item is used in the

enforcement of civil rights laws. For example, the number of

persons in the labor force who are members of different race

groups is an important factor in establishing goals for

affirmative action. When the States draw district lines for

congressional and State legislative seats, they must take race
no

CRS-10

into account co be sure chat they do not violate provisions of

the Voting Rights Act. Information about Che economic and

social progress of persons who are members of different racial

groups is closely watched by various interests. This

information is also used in evaluating the census. NOT CHANCED

5. Age: Age is also one of the factors used in determining Che

completeness of the count. It is vital for tracing the

differences between young and old people and ii used, for

example, in projections of Che resources required for the social

security system. NOT CHANCED

6. Marital status: The respondent is asked if (s)he is married,

separated, divorced, widowed or never married. In 1980, the

census only recognized marriages that occurred after age IS.

During the editing of che returns anyone under age lb who

indicated a marital status other than "never married" was

changed Co "never married." NOT CHANCED

7. Hispanic origin: The Spanish Census Act (PL 9A-311) provided a

congressional mandate for the collection of this information.

It is used for affirmative action and civil rights enforcement.

NOT CHANCED

100Z housing questions are asked about each housing unit and

household in che Nation. Eight subjects are proposed in this

category. Two of them are new [che rest were included in che 1980

census}.

1. Number of units in structure: Respondents are asked to report

the number of housing units in the building. This subject

provides information about the density of housing. It is used

by local governments in determining and monitoring zoning

regulations. It is also important in assessing che need for

mass Cransic and roads. NOT CHANGED

2. Number of rooms in the unit: In combination wich che number of

persons in the housing unit, this subject provides information

about overcrowding which is defined as a housing unit with more

than one person per room. The extent of crowding is a measure

of the need for housing and is used in che allocation of funds

for housing. SHIFTED TO SAMPLE

3. Tenure: Respondents are asked co indicate if they own or rent

their residence and whether it is a part of a condominium. This

information is used in che analysis of che housing market to

separate the owners, renters, and types of owned housing. It is

important in designing the sampling plan for che survey Chat

results in the Consumer Price Index (CPI) because the cost of

rent is a major part of the CPI. According to che Bureau of

Labor Statistics, indexing provisions built into various

provisions of Federal Law mean that a change of 1 percent in the

CPI has a $4.6 billion impact on the Federal budget. These data
Ill

CRS-ll

are also used in setting housing costs for members of the armed

forces. NOT CHANGED

4. Value of the home or monthly rent: Provides detailed 'data about

the relationship of what people spend for rent or mortgage

payments and their income and other characteristics. Used to

set the amounts of money people receive as rent subsidies under

UUD's fair market rent program. SHIFTED TO THE SAMPLE AND ADDED

A QUESTION ON UTILITY PAYMENTS

5. Vacancy characteristics: The follow-up enumerators of the

Census Bureau will compile information about vacant housing.

This information helps account for housing and is a part of

efforts to count each person. The item is also used to identify

places where there is a surplus and shortage of housing. HUD

uses it to plan and implement Federal programs that aid housing.

For example( FHA considers the prevailing vacancy rate when it

decides whether to participate in loans to builders. NOT

CHANCED

6. Plumbing: Respondents are asked whether their housing unit has

indoor plumbing. This is regarded as a measure of housing

quality. Lack of indoor plumbing indicates sub-standard and

unhealthy housing conditions. In 1980, about 2.5 percent of the

Nation's housing did not have plumbing. However, these units

were not evenly distributed over the Nation but concentrated in

certain localities. For example, the last census found that in

II percent of all U.S. counties 10 percent or more of their

housing lacked plumbing. This subject can be used to highlight

neighborhoods where housing is a problem. SHIFTED TO THE SAMPLE

7. Telephone: Including this question saves money in the follow-up

of the census because it makes it possible for the Bureau to use

the phone to call people rather than send out an enumerator.

While the Bureau will report on the number of housing units that

have telephones, the telephone number will not be recorded in

the Bureau's computer's. PRESENCE OF A TELEPHONE WILL BE

SHIFTED TO THE SAMPLE, BUT THE TELEPHONE NUMBER FOR FOLLOW-UP

WILL BE REQUESTED FROM EACH HOUSEHOLD.

8. Congregate bousing: Respondents will be asked to indicate if

their rent includes meals. In the National Content Test less

than 1 percent answered yes to this item. However, the Bureau

may argue that without this subject, its rent statistics would

be inflated. SHIFTED TO THE SAMPLE

Sample population questions are asked about every person living in

households selected for the sample (about 20 percent of the

households) as well as a sample of the persons who do not live in

households. Ten subjects are proposed for inclusion in 1990.

1. Education-enrollment and attainment: The enrollment question

provides detailed information on the number and characteristics
112

CRS-12

of young persons who are at lending and have dropped out of

school. Attainment, shows the number of years of schooling that

each person has completed. This information is used by private

companies in deciding where to locate plants and other

employment centers as well as in their marketing strategy. MOT

CHANCED

2. Place of birth, citizenship, year of entry: This information is

used wherever policies require information about citizenship and

the number of aliens. It is used in planning immigration

policies. It is also used in studies of the pool of persons who

are eligible to vote in elections. NOT CHANCED

3. Ancestry: This question was added in 1980 to provide

information about groups not covered by the race and Spanish

origin questions on the 100Z form. It could be used by any

group that wants to assert a need for special consideration

under the equal opportunity laws. NOT CHANCED

4. Language spoken at home: Identifies the population that has a

difficult time with the English language. It could be used to

identify those persons who require foreign language assistance

in voting or other matters as well as to analyze the need for

special education programs that are aimed at people who do not

speak English. NOT CHANGED

5. Migration: Basic indicator of population movement. Used as a

basis for checking the Bureau's estimates of population between

the census and to understand the reasons for movements and also

to assist in predicting future growth. The information might

also be used to construct samples of people who have moved in

the last five (5) years. For example, anyone wanting to

estimate the number of farmers who have left family farming in

the last five years might start with the responses to this

question. NOT CHANCED

6. Disability: Respondents are asked to identify individuals who

cannot work or travel because of disabilities* It is used to

estimate the number of people who could benefit from special

programs regarding rehabilitation services, vocational

education and anti-discrimination activities. Veterans

Administration uses it to determine where to locate medical

facilities for veterans. NOT CHANCED

7. Fertility: Each women is asked to indicate the number of

children she has borne. This item describes the child bearing

characteristics of the population. It provides a profile of the

levels of fertility of different groups in the greatest degree

of detail and insight on population growth differentials among

groups. MOT CHANCED

8. Veteran status: This item counts the number of persons who have

served in the active armed forces or national guard. The
113

CRS-13

Veterans Administration uses the data as a base line for the

veteran population projections for planning purposes. For

example, it is used to help plan where to put hospitals and

other medical facilities as well as outreach and employment

programs for veterans. NOT CHANGED

9. Employmeni and unemployinent: Provides geographic detail for

information that is regularly collected on the Current

Population Survey. This information is used by BLS as a part of

estimates of employment and unemployment for areas that are

smaller than an entire labor market. Where other currently

collected information is not available BLS uses the census data

together with other information to provide the best possible

estimates for some areas. For example, Cook County, 111. is

disaggregated from Chicago using various sources including

decennial census data. This subject also provides detail for

very rare groups. The Department of Labor and Conmerce use the

resulting estimates to allocate funds under the Job Training

Partnership Act. NOT CHANGED

10. Occupation, industry and class of worker: This information

describes the work done by persons. It is used to evaluate the

work force. For example, in analyses of affirmative action it

is used to determine the supply of persons in different

occupational groups. It is used to project the supply of

persons in highly skilled occupations. State and local

governments use it to determine the need for vocational

education. NOT CHANGED

11. Place of work and comnuting; These are the bench mark data for

local transportat ion planning. Data are used to identify the

need for mass transit and roads and are used for determining the

number of passengers likely to use those facilities.

Respondents are asked where each person living in the household

works, how each gets there and what time each leaves for work.

Used to identify transportation problems that need to be solved.

FEHA uses the information summarized at the work place to plan

for the evacuation of the day time population if this was ever

necessary. These data are also used as a part of the

identification of metropolitan areas and labor market areas.

NOT CHANGED

12. Income in 1969 and work experience: For this subject the Bureau

collects various sources of money income. This subject is the

basis for statements about the number of people living below the

poverty line. Various programs (such as Title 1 of the

Elementary and Secondary Education Act) require its use in funds

allocation. NOT CHANGED

D. Sample housing questions are asked about the households and housing

units that are included in the sample. Ten subjects are proposed for

inclusion in 1990.
114

CBS- U

1. Heating equipwnt and fuels: Used to calculate the amount: of

energy used by households and assess the need for and planning

for energy assistance allocations. It is also used in

anticipating the future requirements of the Nation for energy

and tracking where these requirements are greatest. THREE OF

FOUR QUESTIONS DELETED

2. Source of water mod Method of sewage disposal: Identifies areas

that have housing that nay be hazardous to the safety of the

occupants. Identifies places where new housing could not be

built until emplacement of a water system. NOT CHANGED

3. Autos, light trucks and vans: Used in transportation policy

planning. Department of Transportation uses it to determine

the likely amount of traffic generated by a household. This is

a part of its calculation of the need for highways. NOT CHANCED

4. Kitchen facilities: If a kitchen is not included in the housing

unitt that unit is less suitable for low-income occupancy. This

subject makes ic possible to characterize areas with regard to

the housing quality. NOT CHANGED

3. Year structure built: This question relates to housing quality

and for some Federal grant programs. Data gathered are

informative about housing related infrastructure (such as water

and sewer lines that may have been put in a long time ago). NOT

CHANCED

6. Year moved into residence: This makes it possible to

characterize neighborhoods with regard to their stability.

Newly developed areas can be identified as well as older

changing ones. NOT CHANGED

7. Number of bedrooms: The average rents charged for housing units

in different areas are classified by the number of bedrooms.

This is used to establish fair market rent prices. Data are

used with regard to rent subsidies for low-income families. NOT

CHANCED

8. Farm residence: Data identify farm households. This subject

allows the Census Bureau to prepare extensive analyses of the

characteristics of people who live on farms. NOT CHANGED

9. Housing quality: A new subject for 1990, that would measure

housing quality by asking if there are holes in the floor and

how many tiroes the heating equipment broke down during the past

year. DELETED PRIOR TO SUBMISSION TO OMB OF DRESS REHEARSAL

PROPOSAL

10* Shelter costs including utilities: These ask questions for

total out-of-pocket expense for housing as opposed to just the

mortgage payment or rent. This makes it possible to estimate

the percent of income that is spent on housing. FllA and VA as

well as mortgage lenders examine these data when they set

standards for mortgage eligibility. UTILITIES' PORTION

ELIMINATED
115

C8S-15

APPENDIX 1: CHRONOLOGY OF CONSIDERATION OF THE CONTENT FOR THE 1990 CENSUS
116

CRS-17

APPENDIX 1: CHRONOLOGY OF CONSIDERATION OF THE CONTENT FOR THE 1990 CENSUS

Dace Activity

Apr. I, 1980 Census Day 1980.

Dec. 31, 1980 Census Bureau reported apportionment results from the 1980

census.

Apr* 1, 1981 Figures reported to State legislatures for redistricting

purposes.

1981-1985 Reports of the results from the 1980 census issued by the

Census Bureau.

1982-1985 Census Bureau staff evaluated the results of the 1980 *

census to help decide on improvements needed for the 1990

census.

1983 Census Bureau assembled core staff to begin working on the

1990 census plan.

1964-1965 Census Bureau conducted 65 public meetings in every State

and the District of Columbia to obtain suggestions and

advise regarding the questions that should be included on

the census form.

1984-1985 The Census Bureau conducted pre-tests in Jersey City, New

Jersey and Tampa, Florida in the spring of 1985. OMB

approved the forms on September 26, 1984 and did not raise

objections to Che items.

1984-1985 The Census Bureau organized 10 Federal interagency working

groups consisting of expert representatives from Federal

agencies. These groups reviewed the subjects and made

recommendations as to questions that should be

incorporated. Subjects covered were: housing, general

demographics, race and ethnicity, American Indians and

Alaskan Natives, the institutional population, education,

health and disability, transportation, labor force and

occupation, and income and poverty. The Bureau's proposed

questionoaire reflects the views of these working groups.

Contrary to the practice since 1940, OMB refrained froa

participating in these detailed discussions.

Nov. 1984 OMB convened a Federal Agency Council on the 1980 census

consisting of policy officials who reportedly took a

broader view of census issues and did not consider the

specific justifications for items. This body has not yet

issued a report.
117

CRS-18

APPENDIX 1: CHRONOLOGY OF CONSIDERATION OF THE CONTENT FOR THE 1990 CENSUS

•Continued

Dace Activity

1983-1986 Census Bureau conducted the National Content Test, a sample

survey test of the items it was considering including on

the census form. OMB reviewed this form and approved it

for use on September 30, 1985. The test occurred during

the spring of 1986. Results were reported to OMB in

January 1967.

1983-1986 The Census Bureau conducted pre-tests in Meridian

Mississippi and Los Angeles, California during the spring

of 1986. OMB reviewed the questionnaires for these teats

and approved them on August, 16 1983.

1987 Pre-test held in North Dakota.

Apr. 1, 1987 Census Bureau reported to Congress on the subjects to be

included in the 1990 census questionnaire. Their report

indicated that they would include all of the subjects that

were included in their proposed Dress Rehearsal

questionnaire. OMB approved the report to Congress.

May 14, 1987 The House Census Subcommittee and the Senate Federal

Services Subcoomittee held joint hearings to review the

census content. Dr. Grama testified; said (MB would

carefully review the Dress Rehearsal questionnaire but did

not give any indication of what position OMB/OIRA might

take.

June 16, 1987 Census Bureau submitted the Dress Rehearsal questionnaire

to OMB for approval.

July 1987 Office for the Dress Rehearsal opened in St Louis,

Missouri.

July 24, 1987 OMB raised questions about the need for 301 of the subjects

on the questionnaire*

Aug. 7, 1987 Deadline for the Census Bureau to respond to the OMB

proposal for cuts in the questionnaire.

Sept. IS, 1987 Public comments on the proposed action required by this

date.

Sept. 13, 1987 OMB rejected the Census Bureau's proposed questionnaire for

the Dress Rehearsal and required that they drop three

questions, move others from the 100Z census to the sample

form and reduce the size of the sample from 16 million to

10 million respondents.
118

CRS-19

APPENDIX 1: CHRONOLOGV Or CONSIDERATION OF THE CONTENT FOR THE 1990 CENSUS

•Com inued

Date Activity

Sept. 22t 1987 The Census Bureau submitted a revised proposal for the 1988

Dress Rehearsal questionnaire that reflected all of OMB's

objections except for a compromise on a question on

utilities.

Oct. 28, 1987 OMB approved the modified 1988 Dress Rehearsal form as

required by the Paperwork Reduction Act.

Dec. 10, 1987 The Census Bureau sent a issue paper to OMB advocating the

use of a 1 in 6 sample for the long form in the 1990 Census

to improve census data quality.

Dec. 1987 Census Bureau staff beginning preparations for the

tabulation and publication of the reports from the 1990

Census. This work will proceed on the assumption that no

further changes will be made in the subjects included on

the 1002 and sample questionnaires.

Jan. 1988 President's FY89 budget request will likely contain request

for funds for the bulk of the preparations for the 1990

census.

Spring and Congressional consideration of the Appropriations request

Sutimer, 1989 for the preparations for the 1990 census.

May 1988 Pre-list, the first operation required for the decennial

census begins.

Mar, 20 1988 Dress Rehearsal census day [to be conducted in St. Louis,

Mi ssouri].

Apr. 1| 1988 Census Bureau reports to Congress on the exact wording of

1990 census questionnaire.

June 1988 Census Bureau deadline for submitting 1990 Questionnaire to

OMB for formal clearance.

Oct. 1988 Bids begin for the printing of the 1990 Questionnaire.

Jan. 1989 President's FY90 budget request contains most of the funds

needed for the operations of the 1990 census.

Mar.-Apr. 1989 First local census offices open for checking address lists.

Fall 1989 Most census district offices open and begin work.

Sept. 1989 OMB clearance of the final census forms required by this

date.
119

CRS-20

APPENDIX 1: CHRONOLOGY OF CONSIDERATION OF THE CONTENT FOR THE 1990 CENSUS

•Continued

Date Activity

Oct. 1989 Label tapes submitted to vendors for the printing,

labeling, and assembly of the mailing packages.

Questionnaires are printed at that time.

Nov. 1989 Pre-census local review.

Jan. 1990 Census Bureau reviews and re-canvases areas where local

review has discovered possible problems.

Mar. 23, 1990 Census questionnaires delivered to householders.

Apr. I, 1990 Census Day.

Apr. 2, 1990 Scan capturing data for the computer.

Apr. 26, 1990 Beginning of follow-up operations.

June 28, 1990 Start of field follow-up to fill in information not

provided in the public's mailed responses.

Dec. 31, 1990 Census Bureau transmits population count by State and new

apportionment of the House of Representatives.

Apr. 1, 1991 Census Bureau required to provide the States with detailed

returns including block level counts by race and Hi spani c

origin for use in designating new Congressional and State

Legislative Districts.

July 1, 1991 Reference date of the first intercensal population

estimates required to be produced under 13 USC 181.

1991-1993 Census Bureau will issue reports on the results of the

content of the census.

1992 Host data from the census is available for use by

statisticians working for State and local governments

1993 New statistical procedures are implemented that use 1990

census data as a base.

DM/1jb
120

APPENDIX IV

THE OFFICE OP MANAGEMENT AND BUDGET'S

CHANGES TO THE 1990 CENSUS

A CRITICAL COMMENTARY

written by

PATRICIA C. BECKER

DETROIT REGIONAL CENSUS ADVISORY COUNCIL

In cooperation with the

COUNCIL OF PROFESSIONAL ASSOCIATIONS

ON FEDERAL STATISTICS

TASK FORCE ON THE DECENNIAL CENSUS

and the

HOUSING STATISTICS USERS GROUP

FEBRUARY 19 88
121

THE OFFICE OF MANAGEMENT AND BUDGET'S

CHANGES TO THE 1990 CENSUS

A CRITICAL COMMENTARY

Introduction

The Decennial Census Is, historically, the premier data collection

activity undertaken In this country. Constitutionally mandated to

provide population counts for the apportionment of Congress, the Census

also collects a wide variety of information about the people and

housing of the nation. It is a tool used to allocate human, financial

and material resources. In public and private sector alike, census

data make an essential contribution to understanding, planning, and

decision making.

In July of 1987, operating under the Paperwork Reduction Act, the

Office of Management and Budget indicated that it was considering substantial cutbacks in the scope (content and sample size) of the 1990

Census. In September, after hearing from hundreds of users, 0MB agreed

that many of the content items proposed for elimination should remain.

At the same time, however, a major reduction in sample size was

mandated, from 16.7 million to 10 million households. In general, OMB

has made these decisions against the recommendations of professional

statisticians within the Census Bureau and without specifically

requesting input from data users outside.

If the OMB plan goes forth, the 1990 Census will be a damaged

product, much reduced in usefulness as a tool for the nation's

activities in all those applications which use data beyond the basic

population count.

Background

The decennial census is designed to provide information about a

wide variety of population and housing characteristics. The questions

are divided into two groups. A few basic items are collected for each

person and household. These are called the short form or 100%

questions. The remainder of the questions are asked only of a sample

of the households (and the people living in them)•these are referred

to as the long form or sample questions.

The size of the sample has been steadily reduced since the concept

of sampling was first Introduced In 1940. Until 1960 the long form

was used in one out of four households (referred to as l-in-4 or 25*).

The 1970 sampling plan of l-in-5, or 20*, was to be maintained In 180;

this was later changed to l-in-6 with a larger sample (l-ln-2) in very

small communities, in order to provide adequate data on income for

revenue sharing formula funds distribution.

Prior to the OMB actions of the past few months, the Census Bureau

had announced plans for a l-ln-6 sample across the board for 1990,

since the revenue sharing program has ended. This would have provided

long form Information for about 16.7 million households. OMB has
122

-2-

called for an overall sample of no more than 10 million households,

with a variable sampling fraction.

The purpose of varying the sampling fraction, by size of geographic area. Is to "even out" the error levels. Sampling errors are

tied primarily to the number of cases In the group being analyzed; In

the Census, the long form questionnaires are the cases. The "groups"

used most often In working with census data are geographic areas,

although the issue regarding sample size applies equally to demographic

groups such as blacks, Hiapanlcs, and the elderly.

0MB's Reasons and the Census Bureau's Response

The Office of Management and Budget's intervention in issues of

1990 census methodology is based on its Paperwork Reduction Act

authority. The administrative unit involved is the Office of Information and Regulatory Affairs (OIRA). Wendy Gramm, OIRA Director,

testified In an August 1987 Congressional hearing that Issues of cost

or budget are not primary factors. In a September 16, 1987 letter, OMB

stated that It wants to "Improve the quality of the 1990 census." This

can be accomplished. In Its view, by reducing the sample, especially In

central cities where "nonresponse and response errors have been the

most significant," and by reducing the number of questions on the short

form.

The Bureau of the Census has acceded to OMB's conditions of clearance In order to proceed with the 1988 Dress Rehearsal census. It

appears that OMB Intends to Impose these same conditions for the 1990

census Itself.

OMB Is misguided, however well-intentioned Its reasons may appear

to be. In December, the Census Bureau sent a letter report to OMB,

accompanied by several attachments (hereafter referred to as the

December Report). These materials show clearly that the result of

Implementing OMB's plan will be to make the census worse, not better.

Following are several excerpts from the December Report's Attachment 1.

(Underlining added for emphasis.)

If adopted, the OMB sample size limitation of 10 million

households clearly will decrease the quality of data,

especially for numerically small populations (such as American

Indians, Hispanlcs and the elderly), as well as for most data

publication areas and the vast majority of the population.

The OMB letter [of September 161 also suggests that reducing

the sample size will reduce nonsampllng error and, thus, the

total error in the data. Neither data nor statistical theory

support this contention.

The OMB letter contends that reducing the number of households

that receive the sample questionnaire (or long form) would

Improve the mall return rate and reduce the number of field

enumerators needed to visit nonrespondlng households. We share

the OMB objective of a higher mall return rate, but the Census

Bureau knows from evidence and experience that reducing the
123

-3-

number o£ units that receive the long form to the OMB Unit of

10 million would have a trivial effect on the mall return rate.

In a similar vein, the OMB decision to reduce the number of

questions on the...short form appears to be based on the

assumption that this would Increase the mall return rate for

the form. Our comparison...suggests that the mall return rates

are almost unrelated to the length and content of the

questionnaires. The OMB assumption Is at best

speculative•clearly not a sound basis for making radical

changes In the content of the decennial census.

The December Report goes on to provide substantial supporting

evidence for all of the positions summarized above.

The Bureau of the Census does support changing the sampling plan

from a fixed rate to a variable rate design. However, a sample of

approximately 17.8 million households will be required in order to

maintain error levels, for all geographic areas, at a point no worse

than those provided in 1980. Attachment 2 of the December Report

outlines the design and includes Illustrative levels of relative error

(measured in coefficients of variation, or "CV"), for the various

alternatives. Table 1 provides a summary of this material.

If the constraint to a national sample size of 10 million is

carried out for 1990, using the variable sampling plan outlined by the

Census Bureau in response, the following will be true;

* Even with the plan to concentrate the sample in small

communities (under 1,000 population), there will still be a

very significant data problem in rural areas. Places between

1,000 and 2,500 population will see their error levels more

than double over 1980 levels; other rural communities will

maintain the same high error rates as they had in 1980.

* Half the nation's housing is located in census tracts or block

numbering areas (tracts/BNAs) with between 1,000 and 2,500

housing units in communities of more than 5,000 population. At

a sampling fraction of l-in-10, error levels in these geographic areas will increase by 40 percent as compared to 1980.

* Over one-third of the housing is in the tracts/BNAs with 2,500

housing units or more; most of these have between 2,500 and

3,000 units. At a sampling fraction of l-in-20, error levels

will increase by at least 100 percent.

OMB contends that urban tracts, where there are more likely to be

at least 2,500 housing units, are more "homogeneous" than rural areas.

In fact, census tracts are statistical areas drawn largely by local

committees under Census Bureau guidelines. One of the more important

criteria is continuity--a desire to avoid wholesale changes of the

tract boundaries from one census to another. This works against any

presumed homogeneity of urban tracts and, at best, does little to

guarantee it.
124

This Is especially true In smaller communities where neighborhoods

are snail and several may need to be combined Into one census tract.

In fact, that Is a major reason for the popularity of block group

delineation and use of block group data among planners.

OMB, in Its September 16 letter, required content changes In two

areas. First, most of the housing questions on the short form were

moved to the long form. Second, a few long form questions were

eliminated.

Moving the 100% housing questions to the sample is a serious

mistake. To understand how much of a problem this OMB requirement

creates, we must consider how information is delivered for geographic

areas from the short and the long forms. The smallest level of census

geography is the block. In cities, a block is land, typically a few

acres, and is usually surrounded by streets. In rural areas, blocks

may be several square miles and are defined by roads and other natural

features, such as rivers and streams.

Prior to 1990, block data have been tabulated and published only

in urbanized areas (or where local governments paid for the data). The

upcoming census will provide block data for the entire nation for the

first time. Block-level data have at least three major uses: (1) reapportionment and redistricting, (2) sampling frames for surveys subsequent to the census, and (3) validation of the census to the user. The

first purpose is well understood; the second and third may be less so.

Because blocks typically have small numbers of housing units (most

are under 100), onlv 100% or short form data are provided at the block

level. This is also true for areas aggregated from block level public

data files; a prime example here is the voting precinct. If the rent/

value items are on the long form instead of the short form, there will

be no rent/value data at the block level. This is the only socioeconomic measure available at the small geographic level.

In addition, there is a special problem with two of the questions

to be moved: condominium status and "does the monthly rent include any

meals", a new item designed to identify congregate housing for the

elderly. Housing units in these categories come in "geographic

bunches." That is, a block either has none or it has a lot of units

that are condominiums or are congregate apartments. For this reason, a

primary value of these items is to validate the census itself to the

user, by helping to demonstrate that the data do, indeed, belong in the

geographic place into which they have been tabulated. Having condominium and congregate items on the sample will render them useless for

this purpose and an important use of the census in local planning work

will be eliminated.

The questions soliciting information on the number of rooms and

the complete plumbing facilities are the only items on the census which

address the important issue of housing quality and provide a measure of

substandard housing. Over the years, both lack of plumbing and overcrowding have become less of an issue in urban areas. In the rural
125

parts of the nation, however, a much higher proportion o£ the housing

stock falls to meet minimal standards.

At the same time, because rural areas are small In population and

housing count, error levels on sample Items will be very high. This

will be largely true even with a l-ln-2 sample In the governmental

units under 1,000 population. Most of the rural housing stock Is In

unincorporated areas where the sample will be, at best, l-ln-6 under

the OMB-ordered plan. We might label this a "double whanmy". In which

the rural areas lose both because the Important housing Items are no

longer on the short form and because the sampling errors are high.

OMB ordered eliminated the questions regarding heating equipment,

water heating fuel, and yearly costs of utilities and fuels. This has

been justified, by OMB, on the grounds that the data are available

elsewhere. While the Energy Information Agency (EIA) does collect data

on a monthly basis, and with more accuracy because of its methodology,

these data cannot be made available for small areas. Even areas as

large as 100,000 population cannot be analyzed in the EIA data set.

Further, the question on heating equipment elicits data on the absence

of central heating, an important housing quality measure in many parts

of the country. This, too, has an especially serious impact on

evaluation of rural housing.

This illustrates an Important point which applies to much of the

variety of information collected in the Census. While other data

sources (federal, state and/or local) may provide the same type of

Information, they fall on one or both of two major criteria: (1) the

data are not available for small areas, and/or (2) the data are not

available consistently for all areas In the country. The Census

provides the baseline, the denominator, by which the other sources

(which are typically available at Intervals more frequent than once In

ten years) can be used throughout the decade.

Impact of the Limited Sample Size on Data Products and User Needs

If the OMB's order to constrain the national sample size of 10

million households for the 1990 census, it will be extremely

difficult•we could say, impossible•to provide sample data for the

geographic and demographic groups for which detail Is needed. Some

examples follow:

Block Groups. These geographic units are aggregations of blocks

but are smaller than census tracts and block numbering areas. In 1980,

sample data were provided for block groups in summary tape format (STF

3A). Even at 1980 sampling rates, many Individual block groups were

too small for sample data to be fully reliable. Without a 100* measure

such as rent and value to validate them, and at the proposed reduced

sampling fractions, the relative error levels for block groups will be

so high that, arguably, these files should not be prepared.

One of the major uses of block group statistics has been to Implement portions of the Community Development Block Grant program In the

Department of Housing and Urban Development. HUD prepared 1980 tabulations for all block groups showing the percentage of population that
126

was under the "low-moderate" Income cutoff. Only areas with at least

51% In this category are eligible for "area benefit" block grant expenditures. If these sample data are not available by block group, or

carry error levels so high that they cannot be supported statistically,

continuation of this program will result in misallocatlon of these

local development funds.

Neighborhoods. A popular data delivery program in 1980, planned

for continuation and expansion in 1990, was the aggregation of census

data to user-defined areas such as neighborhoods. In most communities,

where such areas are often smaller than census tracts, the error levels

will be unacceptably high and the program will be severely restricted.

Minority Groups. Because, in most areas, minority groups have

relatively small numbers, the reduction In overall census sample will

harm the data for these groups in both large and small geographic

areas. The data will be so flawed, in most cases, that the publication

program for minority group data should be curtailed. Minority group

tabulations In the census tract report would be unreliable and detailed

summary tape file records would be useful only when there were at least

5,000 people of the group in the geographic area under consideration.

The problem for minority group data has been exacerbated by the

Census Bureau's decision to group together the several ethnic groups

known as "Asian and Pacific Islander" into one question on the short

form. Respondents will be asked to write in the specific group (e.g.

Japanese, Chinese, Filipino), but this information will be coded only

for long form questionnaires. Thus, information on the characteristics of the different Asian ethnic groups at the tract/BNA level will

be very unreliable.

Elderly. Similarly, data for the elderly will be harmed because

they constitute another kind of minority group. On the average,

elderly are only about 10 to 15 percent of the population of a

geographic area. Much of the data currently used to plan programs for

the aged, under the Older Americans Act, will be unreliable at the

geographic detail required for implementation of the programs.

Attachment 3 of the December Report to OMB outlines these and

other implications In greater detail.

Conclusion

The material presented above should make clear that the changes

proposed by the Office of Management and Budget for the 1988 Dress

Rehearsal and, by implication, the 1990 census, are detrimental to

virtually all the purposes for which the census is conducted beyond the

population count. If they hold, the 1990 Census will be a damaged

product.

What can be done about it?

The Paperwork Reduction Act mandates that the clearance process

allow for public comment. However, the time available for review and

clearance often makes substantial Interaction difficult. The result is
127

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that OMB appears to act In a unilateral fashion, superimposing its view

on proposals made by experts from the Bureau of the Census and

elsewhere.

Discussion among expert census data users in the weeks since the

December Report was issued has led to agreement on some issues and

debate on others. What is very clear, however, is that restoration of

the full sample, to a level of at least 16.7 million nationwide, is

necessary to meet data needs across the nation with no inequities.

The variable sampling rate idea has merit, but a large sample is

needed to do it right, along a design such as that proposed by the

Bureau of the Census in its December Report. It must be sufficient to

provide useful data for housing as well as population characteristics

in both urban and rural areas. Among census experts, there is

consensus that a sample size of 10 million households will have a

serious and long-lasting negative effect on the usefulness of the 1990

censos.

The introduction to Attachment 3 of the December Report states:

The foremost criteria which guided the selection of questions

to be included in the 1990 census were (1) that the questions

must provide data with a broadly demonstrated societal need or

data that are needed to administer Federal, state or local

government programs, and (2) that those data must be needed for

relatively small areas •local governments and small statistical

areas--or numerically small population groups. The fundamental

objective of the sample design for the Nation's decennial

census should therefore be to attempt to ensure adequate

reliability for sample estimates for the geographic areas and

population groups for which sample data are needed. The

national sample size constraint of 10 million households

mandated by the Office of Mangement and Budget makes

realization of this objective extremely difficult.

What, indeed, is the purpose of doing the Census as we know it, of

collecting more than the basic population count, if the data are not

usefal for the purposes stated?

We must find a way to turn this around.
128 '

Table 1

Expe cted CV for a

ea

Sampling Rate 10* Housing Item

Type and Size o£ Ar OMB Census OMB Census

1980 Vari- Vari- 1980 Vari- Variable able flhlp able

GOVERNMENTAL UNIT

(population size)

Under 1,000 1/2 1/2 2/3 23.9 23.9 16.8

1,000 to 2,500 1/2 1/6 1/3 11.9 26.6 16.9

CENSUS TRACT/BNA:

(housing unit coun t)

Under 1,000 1/6 1/6 1/3 24.9 24.9 15.8

1,000 to 2,500 1/6 1/10 1/6 16.4 22.1 16.4

2,500 to 3,500 1/6 1/20 1/10 12.2 23.9 16.4

3,500 or more 1/6 1/20 1/12 11.3 22.1 16.9

The Coefficient of Variation places the sampling error in context by

expressing it as a percent of the estimate itself. The data user

can then decide if the estimate from the sample is sufficiently

precise for the intended purpose. The lower the CV, the more

precision in the estimate.

For example, a CV of 23.9 means that the estimate can vary about 24

percent due to sampling error. Since these CV's have been

calculated for a ten percent characteristic, this means that a

reported Incidence of, say, 10% of the households without complete

plumbing facilities, may range in fact from 7.6 to 12.4 percent for

the geographic area and/or demographic group under consideration.

Bear in mind that when the CV would be, say, 23.9 for a census tract

between 2,500 and 3,500 housing units, it would be considerably

higher for a demographic subgroup within the tract, such as blacks,

Hlspanlcs, or the elderly.
129

References

September IS, 1987

Letter from Wendy Gramm, Administrator, Office of Information

and Regulatory Affairs, Office of Management and Budget, to Kay

Bulow, Assistant Secretary for Administration, Department of

Conaerce. This eight page document outlines OMB's conditions of

clearance for the 1988 Dress Rehearsal.

October 28, 1987

Letter from Gramm to Bulow, completing the clearance process

for the Dress Rehearsal with further comments on the sampling frame

issue.

December 10, 1987

Letter from Charles D. Jones, Associate Director, Bureau of the

Census, to Dorothy Telia, Chief Statistician, OMB. Several

documents were transmitted with the letter, as delineated below;

collectively, they constitute what is referred to in this commentary

as the December Report.

December 8, 1987

Memorandum for C. Louis Kincannon, Deputy Director, Bureau

of the Census, from Charles D. Jones, Subject: Census

Bureau's Response to the OMB's October 28. 1987 Letter.

Movember 27, 1987 •

Memorandum for Kincannon from Jones, Subject: Implications

of the Dress Rehearsal Clearance. The memorandum covered

four reports, as follows:

Attachment 1

Observations Concerning the September 16. 1987 Reply

by the Office of Management and Budget to the Census

Bureau's Initial Request to Clear Questionnaires for

the 1988 Dress Rehearsal

Attachment 2

Evaluation of Alternative 1990 Census Sampling Plans.

This Is the document that outlines the Census

Bureau's variable sampling rate proposal for a total

of 17.8 million households.

Attachment 3

Implications of the Proposed 1990 Census Sample

Design tor the Reliability of Sample Data

Attachment 4

Content Issues Concerning the September 18. 1987

Reply by the Office of Management and Budget to the

Census Bureau's Request to Clear Questionnaires for

the 1988 Dress Rehearsal
130

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APPtNOU V

March 14, 1988

The Honorable Edward Roybal

Chairman

House Select Committee on Aging

712 House Office Building Annex I

Washington, D.C. 20515

The Honorable Don Bonker

Chairman

House Select Committee on Aging

Subcommittee on Housing and Consumer Interests

717 House Office BuiIding Annex I

Washington, D.C. 20515

Re: OMB's Changes to the 1990 Census

Dear Chairman Roybal and Chairman Bonker:

OMB Watch is submitting this letter for the record of

the joint hearing held on February 24 by the Select Committee

on Aging and its Subcommittee on Housing and Consumer Interests, "The 1990 Census: Can We Count on It?" OMB Watch is a

nonprofit, nonpart isan research and advocacy group thaft

monitors executive branch activities, particularly those

involving the White House Office of Management and Budget

(OMB).

We commend the Committee and Subcommittee for conducting

a well-focused inquiry into OMB's changes to the "Dress

Rehearsal" for the 1990 Census. The expert witnesses at the

hearing presented important testimony about the staggering

loss of data that will result. To complement their testimony

and your committees' work, we would 1 ike to add to the record

our observations on the OMB paperwork review process and how

it proceeded in this case.

As you know, OMB reviewed the Dress Rehearsal under the

authority of the Paperwork Reduction Act. Passed in 1980,

the Act created the Office of Information and Regulatory

Affairs (OIRA) within OMB to review all federal agency information collection activities affecting 10 or more people.

According to the Act, OIRA should base its paperwork decisions on whether the information to be collected is "necessary for the proper performance of the functions of the

agency, including whether the information will have practical

utility." (44 O.S.C. 3504(c)(2))

Despite the Act's language and despite what OMB would

have people believe, the paperwork review process is far from

an objective management tool for reducing government paperwork. Rather, it has become a powerful -- and largely unaccountable • political weapon that OMB uses to dictate the

substance of what federal agencies do. Couching its decisions with language in the Act as a shield, OMB has used its

paperwork powers to advance political goals (such as deregulation and federalism), thwart the collection of important
131

The Honorable Edward Roybal

The Honorable Don Bonker

March 14, 1988

Page 2 of 5

civil rights information, and reduce the amount of workplace

health and safety information employers must give their

employees -- just to name a few.

On several occasions, including before your joint hearing, OIHA officials explained that they changed the Census

forms because they did not "meet the criteria of practical

utility and minimization of burden established by the [Paperwork Reduction] Act." (Gramm letter, page 2.) What OMB

didn't say is that politics also motivated its decision.

While "practical utility" is among the review criteria

listed in the Act, politics, of course, is not. Yet politics

also motivated this decision. It's no secret that housing is

a sensitive issue for this Administration. It has promoted

massive budget cuts in subsidized housing programs, rejected

other information collection activities regarding the quality

of housing in the United States, and taken other steps to

reduce federal obiigations to provide low-income housing.

The message is clear: The less information the Census collects about housing and Americans' housing needs that aren't

currently being met, the better.

Like politics, cost-'benefit analysis also isn't among

the review criteria established in the Act, Yet OMB officials have used it to defend their decisions. Before your

committees and in other inquiries, OMB officials have pointed

to their statutory mandate to "balance the need for the

information and [its] practical utility . . . against the

burden on respondents and cost involved." (Testimony of

Joseph R. Wright, page 8.)

In reality, there is no such statutory mandate. As

Congress realized when it wrote the Act, the value of information is difficult to quantify, and it'a often much easier

to quantify the costs of collecting information than it is

the benefits. Often, too, the people supplying the information aren't the ones who benefit from its collection.

Another problematic aspect of OMB's paperwork review is

its lack of public accountability. During its review of the

Dress Rehearsal, OMB kept the public in the dark about the

substance of its review until Congress intervened.

Although Congress intended the paperwork process to be

open and publiciy accountable, the truth is that OMB regularly conducts its reviews far from public sight. Had it not

been for a few well-placed phone calls from within the Census

Bureau last July, the public might never have known what

changes OMB had planned for the Dress Rehearsal for the 1990

Census.
132

The Honorable Edward Roybal

The Honorable Don Bonker

March 14, 1988

Page 3 of 5

As a result of the public outcry over news of OMB's

proposals, the Joint Economic Committee (JEC) held a hearing

in August. In testimony at that hearing, then-OIRA Administrator Wendy Gramm made a precedent-setting promise --that

the public comment period on the Dress Rehearsal wouldn't end

until September 15. Never before had OIRA held a defined

public comment period on a paperwork proposal, and it hasn't

since. It seems unlikely it will ever do so again without

significant congressional pressure.

OMB didn't, however, hold any public meetings on its

proposals, as members of your Committee and Subcommittee

pointed out. OIRA officials explained why they hadn't met

with members of the public this way: They "weren't sure

anyone wanted to meet with us."

It's hard to imagine how OMB could reach that conclusion* considering that no less than 1,000 letters poured in

after the comment period was announced. Nonetheless, OMB has

been historically disinclined to hold public meetings on

paperwork • unless industry presses for them.

Only three tiroes in the last seven year has OIRA called

public meetings about paperwork proposals under consideration. Those meetings focused on the Food and Drug Administration 's Medical Device Reporting Rule and the Occupational Safety and Health Administration's Hazard Communication

Standard, two regulations industry has lobbied heavily

against because of their "overly burdensome paperwork requirements. "

In public, OMB officials repeatedly referred to their

"public review" of the Dress Rehearsal; in private, their

actions belied their claims to public accountability and made

a mockery of the notice-and-comment process. They reduced

the public comment period to a meaningless exercise, ironically, in excess paperwork. OMB's ultimate decision on the

Dress Rehearsal is fundamentally at odds with the public

record.

In the time since your joint hearing, OMB Watch has gone

through the 1,000 letters OMB received about its proposed

changes to the Dress Rehearsal. Fewer than 10 support the

OMB position. Obviously, OMB did not base its decision on

the public record.

In her September letter informing the Census Bureau of

OMB's decision, Gramm admitted as much. She easily dismissed

most of the public comments this way:
133

The Honorable Edward Roybal

The Honorable Don Honker

March 14, 1988

Page 4 of 5

"iwle have received comments in our public docket

describing needs for these [housing] data; however,

most commenters expressed concern about outright

deletion of these [housing] items from the census.

Based on these descriptions of user needs, we do

not object to retaining these questions on the long

form." (GraroiD letter to Kathenne Bulow, September

16, 1987, page 5.)

Our search showed that, of a random sample of letters opposing the OMB action, 15 percent specifically expressed opposition to moving the housing questions from the short form to

the long form. Still, the absence of comment on that particular issue shouldn't constitute affirmation of OMB'a

position, especially considering the fact that the possibility of shifting the questions from the short to the long

form was shrouded in the prospect of eliminating them altogether.

Unfortunately, OMB's conduct during the Dress Rehearsal

review is typical. Because Congress doesn't have the resources or time to investigate every instance of OMB paperwork power abuse in every area of federal endeavor on a caseby-case basis, OMB Watch recommends that it should use this

Census example at least to:

• Re-examine and refine the criteria by which OIRA makes

its paperwork decisions. For example, with information

collections 1 ike the Census, for which Congress reviews

the questions, is a second OMB review also necessary?

In other cases. Congress should more specifically define

the review criteria, as well as affirm or deny the

validity of coat-benefit analysis to evaluate information collection activities.

• Allow judicial review of OMB paperwork decisions*

During the debate over OMB's review of the Dress Rehearsal , many people involved have questioned whether the

requirements of the Paperwork Reduction Act take

precedence over the mandate for a census of housing and

population contained in the Housing Act of 1949. The

question remains unanswered. Were OMB paperwork decisions subject to judicial review, the courts could

decide.

• Require that OMB set a defined public comment period for

paperwork proposals, like the regulatory notice-andcomment process required by the Administrative Procedure

Act. While one goal of the Paperwork Reduction Act is

greater public scrutiny over the paperwork process, the
134

The Honorable Edward Roybal

The Honorable Don Bonker

March 14, 1988

Page 5 of 5

Act really does little to put in place the mechanisms to

bring that about.

Again, we commend you for undertaking this review of

OMB's involvement in the Dress Rehearsal for the 1990 Census.

We also thank you for the opportunity to express our perspective on this important matter.

If we can be of further assistance, please do not hesitate to contact us.

Sincerely,

Gwen Rubinstein

Senior Program Associate

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