Report to Congress

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U.S. Census Monitoring Board, Congressional Members

4700 Silver Hill Road, PO Box 610; Suitland, MD 20752

www.cmbc.gov ~ email: feedback@cmbc.gov

Census 2000:

A National Process

Requires Local Focus

Report to Congress

1 February 1999

U.S. Census Monitoring Board

Congressional Members

J. Kenneth Blackwell, Co-Chairman

Dr. David W. Murray

A.Mark Neuman

Joe Whitley, Esq.
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Table of

Contents

Executive Summary

1. Historic Overview

2. Reporting Responsibility

3. Fairness Requires Local Accuracy

4. Correcting Differential Undercounts Requires Local

Accuracy

5. Authorities Question Sampling’s Local Accuracy

6. Post-Census Local Review Improved Local Accuracy

7. Parole/Probation Files Improved Local Accuracy

8. Administrative Records Can Improve Local Accuracy

9. Board Receives Feedback from Local Governments

CONTENTS
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Executive

Summary

Overview

The Constitution of the United States requires that an “actual

enumeration” of the population take place every ten years for the

purposes of apportioning the membership of the Congress. In

1790, the year of the first census, 17 U.S. marshals and their

assistants counted 4 million Americans. Two hundred years later,

in 1990, 300,000 census workers counted nearly 250 million

people, and the vast majority were counted in the right place.

Those results were good – Census 2000 needs to be better. The

countdown to Census 2000 has begun, and that census, like those

before it, will answer two simple questions:

How many people are in the United States,

and where are they located?

The accuracy of the answers to these important questions will

determine whether political representation and public funding in this

country is fair or falls prey to partisan influence or even abuse.

To protect the integrity of the census process, the Congress passed

legislation establishing the Census Monitoring Board, a bipartisan

oversight committee made up of eight members – four appointed by

the Congress and four by the President. This report, the first in a

series of reports by the Congressional Members of the Board,

addresses the issue of fairness and local accuracy in the upcoming

Census 2000 and the Census Bureau’s proposed plans. It also

offers a series of initial recommendations to improve the process.

Because the recent Supreme Court ruling prohibits the Bureau’s

use of statistical adjustment in Census 2000 for apportionment

purposes, this report, with its focus on ways to ensure a better,

more reliable census without statistical adjustment, becomes all the

more important.

We all agree that inequities did occur in the 1990 census that must

be addressed. Of the roughly two percent of people in the U.S.

who were not counted, a disproportionate number were Black,

Latino, Asian or Native American. Most of those uncounted rented

homes or apartments in urban or rural areas. Most disturbing,

more than half were children.
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These were real people who deserved their fair share of political

representation and government funding. Correcting this

disproportionate undercount (the differential undercount) in a way

that assures both the validity of census data and, in particular, the

inclusion of minority communities who have not been properly

represented in the past, is the goal of Census 2000 and a chief

concern of the Congressional Members of the Census Monitoring

Board.

REAL PEOPLE, WHERE THEY REALLY LIVE

The Congressional Members of the Board strongly disagree with

the Census Bureau’s reliance on statistical adjustment. This report

asks and answers a question:

When it comes to the census, if proven methods

can find real people, why do we want to guess?

We don’t; and we don’t have to. Because we have the ability to find

people using local knowledge and local records, we also have the

responsibility to find real people where they really live.

To be of any benefit, the census must find people where they live –

in blocks and neighborhoods.

This is why. Fair shares of political representation and public funds

are distributed according to geographic or political areas – not

demographic groups. If the census determines how many

Hispanics live in California, but not how many Hispanics live in a

Los Angeles barrio, the people living in that barrio still won’t get

their fair share of political representation or public funding for vital

services.

This report contains examples of targeted methods that can add

specific people at specific addresses. These methods offer greater

local accuracy than any statistical adjustment – and a greater

chance for real people to receive their fair share.

In addition to recommendations for a significantly improved census

in 2000, this report also contains a number of preliminary

conclusions concerning what we believe are the roadblocks to a fair

and accurate census.
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Roadblocks to a Fair and Accurate Census

With the January 25 Supreme Court ruling, the census landscape

changed dramatically, but a number of roadblocks still threaten a

fair and accurate census. In fact, the court ruling, while eliminating

the problem of using statistical methods, makes the search for

alternative methods to improve the census all the more urgent.

Several obstacles stand in the way of a truly accurate census:

• The Bureau’s decision to favor national accuracy at the expense

of local accuracy by relying on statistical adjustments that are

increasingly inaccurate in smaller areas.

The Bureau’s preference for a national adjustment approach to

data has put the equitable distribution of federal funds at risk,

particularly to those communities most in need. The resulting

incorrect small-area, or local, data from statistical adjustment

threatens the fair distribution of those funds, or any use of

adjusted numbers at the state and local level. The census must

be a national process with a local focus.

• The almost total reliance on statistical adjustment to the

exclusion of other possible solutions.

This decision by the Department of Commerce has now proven

to be a costly misjudgment wasting time and money – both in

shorter supply as the year 2000 fast approaches.

• The Bureau’s decision to abandon the Post-Census Local

Review, a program included in the 1990 census, to give local

governments a final quality-check of census numbers.

If the Bureau continues down the path toward statistical

adjustment, America could well be facing “dueling” census

numbers – one for apportionment and one for everything else.

In that confusing environment, denying local and state officials

the right to present evidence of undercounts or maldistribution is

unconscionable.
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INITIAL RECOMMENDATIONS –

A ROADMAP TO A BETTER Census 2000

This report offers an initial series of recommendations to help

ensure a better, fairer census for every man, woman and child in

the United States; to take advantage of new technologies; and to

improve cooperation between the Congressional Members of the

Board and the Bureau.

Without sufficient and timely information on certain census issues

from the Bureau, to meet their mandate, the Congressional

Members of the Board aggressively pursued other sources through

hearings, conferences and one-on-one meetings with local and

state officials and others who rely upon federal funds (Chapter

Nine). The feedback from these meetings is reflected in the

conclusions and recommendations found in Chapters Three

through Eight.

Together, these recommendations provide a roadmap – four critical

steps – to a fairer and more accurate census.

1. To supplement traditional census counting methods, the

Bureau should use proven coverage improvements and

utilize new technology.

Ten years ago, the Bureau did not have resources that are

available today which can add to the overall accuracy of the

census, but, even more importantly, can provide essential

information on hard-to-count populations.

• Since 1990, many local and state governments have

developed address databases and mapping systems

comparable or superior to those of the Bureau. GIS

(Geographic Information Systems) which can provide

extremely detailed housing information down to a house-byhouse record of addresses, is just one good example of local

data with the ability to improve national results (Chapter Six).

So is LUCA, (Local Update of Census Addresses), a post1990 program to give local and tribal governments the

opportunity to review and submit updates to the census

mailing list in advance (Chapter Six). If the Supreme Court

has de facto made local accuracy even more important, then
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the Bureau should acknowledge the value of local databases

through its methodologies as well.

• The Congressional Members of the Board also recommend

reinstating the Parolee/ Probationer Coverage

Improvement Program, which added nearly a half-million

real persons to the 1990 census using state and local

records, but has been eliminated by the Bureau (Chapter

Seven). These are some of the hardest-to-count people –

people the Bureau’s proposed Census 2000 adjustment was

supposed to account for statistically. If reinstated, this

program would help find and count them.

• The Bureau can find undercounted children, who

represented 52 percent of the undercount in 1990, using

administrative records. The Congressional Members of the

Board recommend that the Bureau implement aggressive

plans to use state and local social program records such as

Medicaid, Temporary Assistance to Needy Families and

Food Stamps to find and count this underserved population

(Chapter Eight).

2. The Bureau should target its efforts in specified areas

designated as “hard-to-enumerate” in 1990.

Internal reports show that most of the census undercount is

clustered in relatively few geographic areas – almost half of the

hardest-to-count census tracts are located in just 11 cities.

Rather than taking the scattershot approach of national

statistical adjustment which may not be in the best interest of

these areas, it makes more sense for the Bureau to concentrate

more effort in areas where the largest potential undercounts

exists.

Moreover, with the discovery that a large portion of the 2000

undercount is expected to be found in New York City, Chicago,

and Los Angeles, administrative records could play an important

role in eliminating the undercount problems that have

traditionally plagued these cities. Again, count real people

where they really live.
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3. The Bureau should reinstate Post-Census Local Review, a

crucial opportunity for local governments to perform a final

quality-check on census counts in their area.

Despite new technologies and increased sources of state and

local information, Census 2000 will not be perfect. Counties,

cities and other localities depend on local accuracy for their fair

share of government funds and for their ability to distribute the

funds equitably within their own jurisdictions. Also, they have

the capability, thanks to improved databases and local

knowledge, to review their individual census count and report

any mistakes to the Bureau. Losing the Post-Census Local

Review program won’t silence the cries of local governments –

but it will tie their hands.

The Congressional Members of the Board, responding to the

emphatic concerns of local officials, recommend that this

program be reinstated to protect the freedom of due process for

every American community and the integrity of Census 2000.

4. Over the coming year, the Census Monitoring Board and

the Secretary of Commerce should meet on a regular basis

to improve their working relationship; reassess the

Bureau’s focus in light of the Supreme Court ruling; and to

discuss each of the reports as they are released.

Because Secretary Daley and the Congressional Board

Members have never met to discuss these critical issues, the

members ask the Secretary set a date for an initial meeting to

discuss this report and begin a regular dialogue to work together

with the Congress to achieve a better census.
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CONCLUSION

The Congressional Members’ fundamental disagreement with the

Department of Commerce’s plan is not with its objective: counting

every person accurately. Our disagreement is with the means of

achieving that goal.

We favor a dedicated focus of resources, efforts and time on

methods that will improve local accuracy by using new technology

to access new information sources; target geographic areas with

traditional undercount problems for special attention; and open the

census process, before and after, to local and state participation

and input.

To the greatest extent possible, we favor finding real people, where

they really live.
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Chapter

1

The United States has taken a picture of its population every

decade since 1790: the decennial census. Each picture attempts to

answer two questions; How many people are in the United States,

and where are they located? Both answers are necessary to

assign seats in the House of Representatives, ensure fair and

equal political representation, and distribute billions of dollars in

federal and state aid to counties, townships, cities, Native American

reservations, villages and, most importantly, the thousands of

neighborhoods throughout the United States.

After 200 years, the census has answered these questions in

amazing detail. According to the best estimate of the Bureau of the

Census (the Bureau), the 1990 census missed only 1.8 percent of

the population. In 1990, the Bureau located over 248 million people

in the most mobile and culturally diverse population in the country’s

history. Those results were good – but Census 2000 must be

better.

The Bureau determined the 1990 count fell short by roughly 4.7

million people (less than two percent of the total population).1

 The

 

1

 For the past five censuses, the Bureau has measured the total population

through demographic analysis, a process that answers “How many people?” at

the national level. Demographic analysis simply uses administrative records to

add births, subtract deaths, and account for immigration to produce a national

total. It also produces a reliable measurement of the undercount of Black

Americans. Unfortunately, demographic analysis does not answer “Where?”

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Bureau candidly reported that those results were disappointing,

because the 1990 undercount was larger than the previous census

(in 1980). The results also continued an alarming trend: those left

uncounted were disproportionately from minority, low-income or

urban communities. About half were children.

The Bureau’s success counting some groups more than others is

known as the differential undercount. The Bureau reported

disproportionate undercounts of African-Americans, Hispanics,

Asians and American Indians. In a country that strives for fairness

and equality, particularly in political representation, the differential

undercount is a grave concern for the census. With its suggestion

of racial inequality, it is certainly one of the most controversial

concerns.

However, analysis indicates that race is coincidental with other

factors, such as location, that produce census undercounts. The

Bureau lists several characteristics typical of undercounted areas,

including mobile populations, language barriers, and irregular

housing. According to the Bureau, “Because higher proportions of

the nation’s children, renters and minorities live in these situations,

it should not be surprising that their undercount rates are higher.”2

Since 1990, the Bureau has made efforts to improve the census as

a whole, and specifically to improve census-taking in areas prone to

high undercounts.

As a result, Census 2000 will be substantially different from 1990.

For the first time, the Bureau will not build its address list from

scratch, instead revising the 1990 address list with the help of the

U.S Postal Service and local governments.3 This also marks the

first time the Bureau’s list has been open to full review by local

 

since birth and death records do not locate people within states and smaller

areas.

2

 Department of Commerce, Bureau of the Census, Report to Congress – The

Plan for Census 2000 (Washington, DC, August 1997), 6. 3

 Since 1970, the Bureau has mailed a census form to most known residences in

the country. The vast majority of people counted in the census are counted

because they voluntarily fill out and mail back those forms. As a result, an

accurate and comprehensive address list is generally cited as the single most

important aspect of a successful census. That will not change in 2000. The

census address list is known as the Master Address File (MAF). In 2000, the

MAF will list approximately 118 million addresses.
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governments.4 The census form itself has been simplified, and a

$100 million advertising campaign has been planned to increase

mail response. Census 2000 will use new character-recognition

technology to “read” and record census forms faster. For 2000, the

Bureau plans to increase partnership efforts with local governments

and community organizations. Some of those partnerships are

already in place.

However, the most controversial change proposed for Census 2000

involves the use of statistical sampling to adjust census numbers.

In 1988, cities, states and individuals, led by New York City, filed

suit to force the Bureau to adjust the population counts – add and

subtract people – according to the results of a statistical sample.

The proposed sample was the Post Enumeration Survey (PES), a

sample of 170,000 households designed to measure census

coverage.

The Secretary of Commerce decided the statistical methodology

was too inaccurate and unreliable to adjust the 1990 numbers. In

1992, a high-level Bureau committee confirmed the Secretary’s

reservations, reporting that about half the PES adjustments were

erroneous.5

 In 1996, the Supreme Court also supported the

Secretary’s decision not to adjust using sampling.6

However, the Bureau continues to build on the example of the 1990

PES. Encouraged by recommendations from two panels convened

 

4 PL 103-430, § 2(a) (31 October 1994) 5

 Department of Commerce, Bureau of the Census, Committee on Adjustment of

Postcensal Estimates (CAPE Committee), Assessment of Accuracy of Adjusted

Versus Unadjusted 1990 Census Base for use in Intercensal Estimates

(Washington, DC, 7 August 1992). The CAPE Committee was formed in 1991.

Meeting regularly with the Director of the Census, this “senior level group of the

Bureau of the Census statisticians and demographers” was to determine whether

the sampling methodology rejected for adjustment in the 1990 census could be

refined for use in intercensal population estimates, which are not used for

apportionment.

6

 In Wisconsin v. City of New York, et. al., the Court ruled the Secretary’s

reasoning was sound, and the decision not to adjust was “a reasonable choice in

an area where technical experts disagree.” One of the main points of the

Secretary’s reasoning was that while a PES adjustment might improve numerical

accuracy at a national level, it would not improve distributive accuracy at state

and local levels. In other words, the PES might answer “How many?” but would

not answer “Where?”
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by the National Academy of Sciences, the Bureau developed plans

to adjust Census 2000 according to a similar, larger statistical

survey.

During budget negotiations in November 1997, debate over the

census resulted in Congress’ and the Administration’s compromise

on preparations for Census 2000. Legislation directed the Bureau

to continue preparing for Census 2000 on two tracks: one using

statistical adjustment, the other attempting a full enumeration.7 The

same legislation provided for expedited appeal of lawsuits over

plans to use statistical adjustment in Census 2000.

On January 25, 1999, the Supreme Court ruled, prohibiting the use

of sampling for the purposes of Congressional apportionment in

Census 2000. The Secretary of Commerce quickly asserted plans

to use statistical adjustment – yet another post-enumeration survey

similar to the one attempted in 1990 – to alter the results of Census

2000 for the purposes of everything other than apportionment.

Disagreement over the accuracy, constitutionality and political

consequences of the Department of Commerce’s renewed proposal

to use statistical adjustment continues the heated debate between

politicians, lawyers and statisticians. Although the arguments are

often reported in primary colors, the issues offer a full palette of

legal, political and academic opinion. They range from the

broadest questions of constitutional authority, to the finest points of

mathematical minutiae. Reasonable people can, and do, disagree

on many of them.

The same legislation that expedited the Court’s review also

established the Census Monitoring Board, an eight-member

bipartisan oversight committee charged “to observe and monitor all

aspects of the preparation and implementation of the 2000

decennial census.” Four (Congressional) members were appointed

by leadership in Congress. Four (Presidential) members were

appointed by President Clinton.

 

7

 During budget negotiations in November 1998, Congress and the Clinton

Administration again compromised over the census, requiring further legislative

action to continue funding to Commerce, Justice and State Departments past 15

June 1999. The Bureau of the Census budget is contained in the Department of

Commerce appropriation.
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Due to delays in the Presidential appointments, the Board

convened for the first time on June 3, 1998. Staff were hired

shortly thereafter, and full operations began in July 1998.

Co-Chairman and Ohio Secretary of State J. Kenneth Blackwell

leads Congressional members Dr. David Murray, A. Mark Neuman

and Joe Whitley, Esq. Their Presidential counterparts, led by

Co-Chairman and former U.S. House Majority Whip Tony Coelho,

are Gilbert Casellas, Esq., Dr. Everett Ehrlich and Lorraine Green.

This report, the first in a series required by statute, represents the

Congressional members’ efforts, in six months, to overtake an

argument that has raged for more than ten years, over two

questions that have been posed for two centuries: How many

people are in the United States, and where are they located?
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Chapter

2

Arguments over the census often concern accuracy – how accurate

are the numbers? In the context of the census, “accuracy” has two

components: numerical accuracy and distributive accuracy.

Numerical accuracy means determining the correct number of

people in the country or region. Distributive accuracy means

determining where, exactly, those people are.

In 1996, the Supreme Court ruled that counting the number of

people in the census is less important than locating where they are.

In a unanimous opinion, the Justices wrote, “a preference for

distributive accuracy (even at the expense of some numerical

accuracy) would seem to follow from the

constitutional purpose of the census, viz.,

to determine the apportionment of the

Representatives among the States.” 8

In other words, accurate state and local

counts are more important than an

accurate national count. The Court and

the Secretary of Commerce both noted

that the proposed statistical adjustment in

1990 was progressively less accurate at

smaller levels of geography.

Questionable local accuracy was a major

reason for the Secretary’s decision not to

adjust the 1990 census, and the Court’s

support of that decision in 1996.9

In 1997, the National Academy of Sciences reported, “With any

reasonable sampling scheme that might be used nationally, there

will be some levels of aggregation (for example, census blocks) for

which the census count would be less precise on average....”10

 

8 Wisconsin v. City of New York (1996). 9

 Ibid. “the primary criterion for accuracy should be distributive accuracy – that is,

getting most nearly correct the proportions of people in different areas.”

10 Preparing for the 2000 Census: Interim Report II, ed. Andrew A. White and

Keith F. Rust, by Panel to Evaluate Alternative Census Methodologies,

(Washington, DC: National Academy Press, 1997), 11.

REPORTING RESPONSIBILITY

To date, we

have seen no

evidence that

distributive

accuracy

(local

accuracy) has

been improved

in any plan for

statistical

adjustment of

Census 2000.
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In November 1997, Congress listed the concern over local

accuracy first among the reporting requirements for the Census

Monitoring Board. The statute reads:

(2) In addition to any matter otherwise

required under this subsection, each

such report shall address, with respect

to the period covered by such report –

(A) the degree to which efforts of

the Bureau of the Census to

prepare to conduct the 2000

census—

(i) shall achieve

maximum possible

accuracy at every level

of geography;

11

In 1998, the Associate Director of the Decennial Census reported

continued difficulties with the Bureau’s plans to make statistical

adjustments to small areas.12

To date, the Congressional Members of the Census Monitoring

Board have seen no evidence that distributive accuracy (herein

referred to as local accuracy) has been improved in the Department

of Commerce’s plan for statistical adjustment of Census 2000.

Additionally, the plan for a non-adjusted census eliminates

programs that have improved local accuracy in previous censuses.

This report focuses on the issue of local accuracy.

 

11 PL 105-119, § 210(f)(2)(A) (1997) 12 John Thompson and Robert E. Fay, Department of Commerce, Bureau of the

Census, Census 2000: The Statistical Issues, (Washington, DC, 1998). “[T]here

will be an issue of how far the ICM data can be disaggregated geographically.

For example, in a strict state-based design, there will be too little data to support

a separate Hispanic estimate within many states, and the proposed approach of

combining races, such as Blacks and Hispanics, provides a less direct estimate

than the separation of these groups in the 1990 PES. There will be additional

difficulty in measuring undercount for other racial groups...”
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Chapter

3

In December 1998, Sacramento City Council member Lauren

Hammond illustrated how fair and sensible distribution of federal

funding relies on accurate local census numbers. Councilwoman

Hammond testified to the Census Monitoring Board that the severe

undercount in her district13 – a predominantly African-American

area – resulted in insufficient

resources for a much-needed

middle school. She testified

that, although the 1990

census showed 46,000

people in her district, the

actual population is closer to

60,000, and cited Bureau

reports that children were

severely undercounted in

1990.14

Councilwoman Hammond

testified, “There might be

some programs that need to

be geared towards this particular ethnic group [African-Americans].

It is not reflected in the census, and the censuses are the only

official numbers that we can use. ... I have four high schools and

eight elementary schools and not one darn middle school because

there aren't the numbers to reflect that. So a 2.9 percent

undercount in Sacramento might seem insignificant. But many of

them are children, are people who need more government

resources than maybe perhaps other folks.”15

 

13 Most local districts are less than a tenth of the size of a congressional district.

Many are only a few thousand or a few hundred people. Since local government

units are smaller, the need for block level data for local redistricting is actually

greater. At these sizes, small differences in the population can result in very

large percentage deviations.

14 Department of Commerce, Bureau of the Census, Report to Congress – The

Plan for Census 2000 (Washington, DC, August 1997), 3. 15 U.S. Census Monitoring Board, Public Hearing, 16 December 1998.

FAIRNESS REQUIRES

LOCAL ACCURACY

Thousands of local

communities – not just

big cities and states –

now rely on accurate

local census data to

direct a fair share of

billions of federal dollars

and millions of state

dollars to their schools

and neighborhoods.
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Ms. Hammond’s missing middle school is not a constitutional

problem (the Constitution does not require that census numbers be

used to distribute funds), but it is a serious one. Over the years,

additional uses of census numbers have grown enormously.

Thousands of local communities – not just big cities and states –

now rely on accurate local census data to direct a fair share of

billions of federal dollars and millions of state dollars to their

schools and neighborhoods.16 The Bureau has an obligation to

ensure the most accurate numbers at the smallest levels of

geography: neighborhoods and blocks.

Accurate block data also ensures the constitutional obligation of the

census: fair political representation. Fair representation is

fundamental to American government: every person’s vote counts.

Voting districts — such as Congressional, state legislature, city

council and school board districts — must represent equal numbers

of people. The only way to ensure that they do is to use accurate

local data on the population in each district.

Article I, section 2 of the Constitution mandates the decennial

census, reading, “The actual enumeration shall be made within

three years after the first meeting of the Congress of the United

States, and within every subsequent term of ten years, in such

manner as they shall by law direct.”17

The Constitution also directs that the results of the census be used

to apportion the Members of the House of Representatives among

the States. Article I, section 2, reads, “Representatives ... shall be

apportioned among the several states ... according to their

respective numbers...” The 14th Amendment reads,

“Representatives shall be apportioned among the several states

according to their respective numbers, counting the whole number

of persons in each State ...”

 

16 For all practical purposes, the census is the major source of information federal

agencies can use to distribute funds nationally. In 2000, federal agencies will

distribute an estimated $182 billion in aid through 20 programs using census

data. In 1998, Medicaid alone distributed an estimated $104.4 billion using

census data, and Title I grants for local education anticipated distributing $7.5

billion.

17 Constitution, art. I, §2, cl. 3.
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In 1911, Congress fixed the number of U.S. Representatives at 435

– one per state and the rest apportioned. As a result, if one state

gains a representative, another state must lose one. “In 1990,

differences of fewer than 10,000 persons determined which states

got the 434th and 435th seats (and which did not).”18

Drawing the districts that congressional seats represent – putting

lines on a map – depends on knowing where people are within a

state, so districts can be drawn around equal numbers of people,

and each seat will represent an equal population. Locating people

where they live is, therefore, essential.

Congressional districts are rarely uniform in size. Areas with

denser populations have smaller congressional districts. Areas

with sparse populations can be geographically huge. Montana and

North Dakota, for instance, have only one congressional district

each. California has 52. The more population recorded in an area,

the more districts drawn in that area.

In the 1960’s the Supreme Court started a revolution in drawing

districts: the concept of “one person, one vote.”19 The Court held

that congressional districts within states must be equal “as nearly

as practicable.”20 For example, a hypothetical state with a

population of ten million people – divided into ten congressional

districts – should ideally have one million people in each district.

This standard has been reinforced repeatedly. In 1983, the Court

found that even small, mathematically insignificant variances

between districts can be objectionable.21 As a result of this ruling

and the precision of computerized redistricting software, nearly all

 

18 Choldin, Harvey, Looking for the Last Percent (New Brunswick, NJ: Rutgers

University Press, 1994), 232.

19 Baker v. Carr, 369 U.S. 186 (1962). “One person, one vote” was actually

coined in Gray v. Sanders, 372 U.S. 368 (1963) which upheld, extended and

clarified the Baker ruling. “One person, one vote” has two distinct branches, but

both demand distributional (i.e. local) accuracy in the census.

20 Wesberry v. Sanders, 376 U.S. 1 (1964) 21 Karcher v. Dagget, 426 U.S. 725 (1983). Although the difference between the

largest and the smallest districts in New Jersey was less than one percent (less

than the national undercount), and on average each district varied from the ideal

population by only 0.1384 percent, the Court found the differences in size of

districts was not the result of a good-faith effort to achieve equality.
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congressional districts drawn after the 1990 census were within a

few dozen people of others in the state.22 This precision is only

achievable by constructing districts at the block level.

The Bureau claims that block-level data is unnecessary for

constructing districts, because districts actually contain many

blocks. This claim ignores the fact that districts are drawn

precisely, block-by-block, to ensure equal population and fair

representation. It also ignores evidence that suggests blocks with

high undercounts tend to cluster together. For instance, several

adjacent blocks in inner-city Chicago will each tend to have high

undercounts, and several adjacent blocks in the suburbs will each

tend to have low undercounts. As a result, whole neighborhoods in

the inner-city will tend to have higher undercounts than

neighborhoods in the suburbs.23 If the inner city neighborhoods are

placed in one congressional district and the suburban

neighborhoods in another, the differential undercounts in these two

areas will result in unfair representation.

The third legal point that ensures equal representation is the Voting

Rights Act. The Act demands accurate block level data about race

and ethnicity because it protects equal representation of minorities.

 

22 David C. Huckabee, Congressional Research Service, Library of Commerce,

Congressional Redistricting: Federal Law Controls a State Process (Washington,

DC, 20 December 1993), 32.

23 The Bureau plans for Census 2000 include a “planning database” in which the

Bureau “... assembles a range of housing, demographic and socioeconomic

variables that are correlated with nonresponse and undercounting.” The

database provides a systematic way to “identify potentially difficult-to-enumerate

areas ... for special attention in 2000.” J. Gregory Robinson and Antonio Bruce,

The Planning Database: Description and Examples of its Targeting Capability

(Washington, DC: Department of Commerce, Bureau of the Census, 18

September 1998 (revised 5 October 1998)), 2.
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Chapter

4

A differential undercount occurs when a higher-than-average

proportion of a certain group24 is left uncounted in an area.25 For

example, if Hispanics were undercounted by

six percent in the Miami area, and the overall

undercount for that area was only four percent,

then Miami-area Hispanics would be subject to

a differential undercount. As a result, they

would lose political representation unfairly,

since they would not receive a share of

political influence (locally or nationally)

proportional to their numbers. Since political

representation at every level is based on local

population numbers, local differentials are the

greatest threat to fair representation.

National numbers reflect these local

undercounts – including an alarmingly high

undercount of children.26 The Bureau reports that urban or rural

areas with high renter populations tend to have high undercounts.

 

24 To achieve fairness in voting and funding, the groups of interest are racial and

ethnic. Although the Bureau wants the most accurate count of the whole

population, and a differential undercount of any group weakens the usefulness of

the census, there are no special imperatives to address some undercounts. For

instance, the fugitive population or the “deadbeat-dad” population are most surely

differentially undercounted, and probably always will be. However, fugitives and

deadbeat dads, unlike many racially and ethnically concentrated neighborhoods,

do not vote together, or generally share similar social and cultural values.

25 The undercount rate for a group is the percent by which the count for that

group falls short of the true count. One measure of the differential undercount

for a group is the absolute difference between the undercount rate for that group

and the overall undercount rate. If the Hispanic undercount rate is reduced to 3

percent and the overall undercoverage rate to 2 percent, then the differential

undercount is reduced to |.03 - .02| = .01 .

26 Department of Commerce, Bureau of the Census, Report to Congress – The

Plan for Census 2000 (Washington, DC, August 1997), 3. “While children under

the age of 18 represented 26 percent of the total national population [in 1990],

they accounted for 52 percent of the undercount.”

CORRECTING DIFFERENTIAL

UNDERCOUNTS REQUIRES

LOCAL ACCURACY

Adding

people to

national or

state counts

without

adding them

where they

live would

only cover

up the

problem.
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Also, areas with high immigrant populations where English is a

second language are prone to undercount. The Bureau finds that,

since disproportionate numbers of Hispanics, Asians, AfricanAmericans and other minority groups live in these hard-toenumerate areas, those groups tend to have higher undercounts

nationally.27

Adding people in the neighborhoods where they were missed in

1990 – urban neighborhoods, with high populations of minorities

and renters – will reduce the overall differential undercount of

minorities in the census. However, adding people to national or

state counts without adding them where they live would only cover

up the problem.

A simple example illustrates why it is necessary to add people

where they live. The 1990 census missed roughly one out of every

12 African-American28 males (in general, the census only missed

one in more than fifty people, nationally). This particular differential

undercount could easily be corrected nationally by going through

the census and adding an African-American male for every dozen

African-American men actually counted. Problem solved – at the

national level.

Unfortunately, this “solution” would do nothing to improve the

undercount, or the quality of life, in New York City’s East Flatbush,

for instance, where the undercount of African-American males was

significantly higher than one-in-twelve. In fact, the wrong

adjustment would be worse than no adjustment, because it would

give the false impression of solving the problem, while the residents

of East Flatbush would be no better off.

Thus, it is not just national undercounts that are important, but the

local distribution of undercounts. Distribution is important because

differential undercounts are not distributed evenly throughout the

nation or a state. They vary from area to area. For example,

 

27 Department of Commerce, Bureau of the Census, Report to Congress – The

Plan for Census 2000 (Washington, DC, August 1997), 6. 28 The 1990 census recorded “Black,” rather than “African-American,” under the

questions concerning race. That has changed on the 2000 questionnaire.

Question 8 on the current questionnaire lists “Black, African Am., or Negro” as an

option. Department of Commerce, Bureau of the Census, United States Census

2000 (Washington, DC, 1998).
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Robert Taylor Homes, public housing along Chicago’s Dan Ryan

Expressway, will likely have a much higher differential undercount

of African-American males than Bridgeport, a predominantly white,

middle-class neighborhood located just across the expressway.

Therefore, any plan to reduce the differential undercount in Chicago

needs to locate people in Robert Taylor Homes, without adding

people erroneously to nearby Bridgeport. Otherwise, Bridgeport

will benefit from population wrongfully subtracted from Robert

Taylor Homes – the area with the greatest undercount. Likewise,

any plan to reduce the differential undercount must target local

areas such as neighborhoods, where the problem occurs and

where a solution will help.
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Chapter

5

Census Bureau Director Dr. Kenneth Prewitt publicly noted the

importance of local accuracy in Census 2000, describing the

census as an effort to find approximately 275 million residents “and

make certain we know where they are living on April1st...it’s both a

huge count, of course – it’s everyone – but it’s also a count that has

to identify residency as of that date, because it is residency that

determines allocation of congressional seats, state legislative seats

and, of course, federal funds.”29

Dr. Prewitt’s emphasis on local accuracy seems out of step with the

Bureau’s enthusiasm to adjust census numbers by statistical

sampling. History and analysis have repeatedly questioned the

ability of the Bureau’s statistical adjustment techniques to provide

accurate block-level data in the census. The Secretary of

Commerce did so in 1990; the Supreme Court did so in 1996;30 top

Bureau officials did so in 199231 and again in 1998;32 noted

statisticians and demographers did so in 1998.33 In 1997, the

National Academy of Sciences reported, “With any reasonable

sampling scheme that might be used nationally, there will be some

levels of aggregation (for example, census blocks) for which the

census count will be less precise on average and would arguably

 

29 “The Diane Rehm Show” on National Public Radio, WAMU in Washington, DC,

11 January 1999.

30 Wisconsin v. City of New York (1996). 31 Department of Commerce, Bureau of the Census, Committee on Adjustment of

Postcensal Estimates (CAPE Committee), Assessment of Accuracy of Adjusted

Versus Unadjusted 1990 Census Base for use in Intercensal Estimates

(Washington, DC, 7 August 1992), 1.

32 John Thompson and Robert E. Fay, Department of Commerce, Bureau of the

Census, Census 2000: The Statistical Issues, (Washington, DC, 1998). 33 Congress, House, Subcommittee on the Census, Hearing on Oversight of the

2000 Census, 106th Cong, 2nd sess., 17 September 1998. Statements of Leo

Breiman, Professor Emeritus of Statistics, University of California at Berkeley;

Donald Ylvisaker, Department of Statistics, UCLA; Robert A. Koyak, Ph.D.,

Assistant Professor of Operations Research, Naval Postgraduate School; Martin

Wells, Cornell University; Lawrence Brown, Meiers Busch Professor of Statistics,

University of Pennsylvania.

AUTHORITIES QUESTION

SAMPLING’S LOCAL

ACCURACY
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not be an improvement over what could be obtained without the

use of sampling.”34

Former Bureau Director Barbara Bryant summarized the problem

when she reported the findings of a group of the Bureau’s highlevel statisticians and demographers, writing, “Their work [CAPE

committee] suggests that no survey – either the high-quality, well

controlled and interviewed 1990

PES of 170,000 households or a

larger one – can be used to make a

post-census fine tuning of an

average undercount as small as 1.6

percent in all types of places,

counties and states at a level of

accuracy beyond that by which

surveys are usually judged.”35

The statistical adjustment proposed

for Census 2000 is a version of the

adjustment plan rejected for

Director Bryant’s 1990 census.36

Many of the failings of the rejected

1990 plan remain unsolved in the present plan.37 Although the

Bureau has been working to reduce or eliminate those problems,

critical deficiencies remain.38 To be sure, modifications as a result

of the 1998 dress rehearsals may yet improve matters. However,

 

34 Preparing for the 2000 Census: Interim Report II, ed. Andrew A. White and

Keith F. Rust, by Panel to Evaluate Alternative Census Methodologies,

(Washington, DC: National Academy Press, 1997), 11.

35 Federal Register, (Washington, DC, 4 January 1993), vol. 58, no. 1, docket no.

920897-2347.

36 When asked the difference between the PES (1990 sample) and the ICM

(2000 sample), Bureau officials consistently cited the ICM’s larger sample size.

Although the national sample is five times larger, 750,000 households in 2000

compared to 170,000 in 1990, this assertion is misleading. Since the Bureau has

decided to employ direct sampling of states in 2000, the 750,000 households in

2000, unlike in 1990, will be divided into separate samples for each of the 50

states and the District of Columbia. The total sample size for any one state in

2000, then, will be much, much smaller than the sample used in 1990.

37 Lawrence D. Brown, et al, Statistical Controversies in Census 2000, (Berkeley,

CA: Department of Statistics, 25 August 1998), 20.

38 John Thompson and Robert E. Fay, Department of Commerce, Bureau of the

Census, Census 2000: The Statistical Issues, (Washington, DC, 1998), 8.

Before the

doubts

about local

accuracy are

resolved, it

would be

premature to

adjust local

counts

using

sampling.
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Congressional Members of the Census Monitoring Board have

seen no evidence to date that suggests a statistical adjustment in

2000 will perform demonstrably better than it would have in 1990.

Therefore, it remains an open question, requiring additional

research and analysis, to determine at what geographic level, if

any, adjusted counts might yield improved distributive accuracy

over unadjusted counts. Before the doubts about local accuracy

are resolved, it would be premature to adjust local counts using

sampling.
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Chapter

6

Building public confidence in the census is essential to the success

of the census. Nothing undermines that confidence more than the

Department of Commerce’s decision to eliminate Post-Census

Local Review – an opportunity for state and local governments to

perform a quality check of the census numbers before they are

final. The Department of Commerce’s refusal to reinstate PostCensus Local Review demonstrates a lack of sensitivity to

concerns of state and local governments.

In light of the doubts cast on the local accuracy of the Bureau’s

adjustment plan, responsible representatives should look for better

ways to ensure people are counted in the neighborhood where they

live. Post-Census Local Review, a program included in the 1990

census, is one way to provide local

governments with a final quality-check of

census numbers.

During the 1990 census, the Bureau offered

local and tribal governments both pre-census

and post-census reviews of housing counts in

their area. During post-census review, the

Bureau reported the number of housing units

counted in each block prior to releasing the

final numbers. Counties, cities and other

localities had 15 business days to check these

counts for accuracy.

Former Director of the Census Bureau Barbara Bryant wrote that,

“Overall, 17 percent of local governments, including the 51 largest

cities in the country, challenged our counts. Seven cities claimed

an undercount of housing units on more than 2,000 blocks.”

According to Director Bryant, Post-Census Local Review ultimately

added nearly 500,000 people to the census.39 As the result of postcensus coverage improvements, Detroit, Michigan added over

 

39 Barbara Everitt Bryant, Moving Power and Money: The Politics of Census

Taking, (Ithaca, NY: New Strategist Publication, Inc., 1995), 138.

POST-CENSUS LOCAL REVIEW

IMPROVED LOCAL ACCURACY

Building

public

confidence

in the

census is

essential to

the success

of the

census.
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47,000 people, mostly inner-city residents, to its total. Cleveland,

Ohio added more than 10,000 people.40

At the time of this report, Post-Census Local Review is not part of

any plan proposed by the Bureau for Census 2000.

Current Bureau officials contest Director Bryant’s assessment of

Post-Census Local Review, citing fewer true “adds” to the census

count. In fact, many of the corrections made by the 1990 review

included relocating people to the accurate place – subtracting them

from the wrong block and adding them to the correct block. For the

purpose of determining local funding, such an addition could be

more valuable, because it would keep resources from being

mistakenly allocated to a nearby jurisdiction.

In 1990, the Bureau listed compelling reasons to offer local review.

“Most important is that local officials have an opportunity to review

the maps and counts while the census is still in progress. Possible

errors identified and reported at this stage are relatively easy to

check and correct if necessary. Once this stage is passed,

problems can become difficult to resolve....The officials of local and

tribal governments that choose to participate also will have a better

understanding of the procedures and concepts involved in taking a

census. A considerable amount of good will and understanding of

one another can develop between the governmental unit, the state

agencies assisting the governmental units, and Census Bureau

personnel as a result of the interaction during the local review

program.”41

These benefits – a more accurate census and local buy-in to the

process – are no less compelling for 2000. Mayor David Kehoe of

Redding, California, writes in a letter to the Board, “precensus and

postcensus review of unit counts is just as crucial in the year 2000

count as it was in the last decennial.” With the introduction of new

and disputed methodology into Census 2000, efforts which promote

 

40 The Board has requested a complete list of localities that participated in 1990’s

review, and the number of people added as a result. The Bureau responded with

a request for payment of $15,000 for this information, which the Board is

considering. In the meantime, the Board has relied on public records, media

reports and direct interviews for specific information.

41 Department of Commerce, Bureau of the Census, 1990 Decennial Census

Local Review Program Information Booklet (Washington, DC, 1987), 4.
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local participation and confidence would seem to be more, not less,

important to the census.

There is reason to believe that Post-Census Local Review would be

more successful in 2000 than in 1990. In 1994, urged by local

governments dissatisfied with limited input in the 1990 census,

Congress passed the Census Address List Improvement Act. As a

result, the Bureau can now

share individual addresses

with local governments (for

the purpose of review only).

One result is the LUCA

(Local Update of Census

Addresses) program,

wherein local and tribal

governments review and

submit updates to the

mailing list prior the census.

Building on the benefits of LUCA, the possibility of reviewing

specific addresses promises significant improvement to PostCensus Local Review. In 1990, the Bureau provided local

governments with the number of housing units in an area, but not

their addresses. In order to correct those numbers, local leaders

generally needed to finance a special census of their area.42 This

burden could be reduced by the Bureau providing detailed address

lists. For instance, a mayor or city planner relatively familiar with

the area would not need a local census to point out to the Bureau

that the 800-block of North Main Street was missing from the

census list.

Correcting the census counts during Post-Census Local Review

would also continue the working relationship formed between local

officials and Bureau employees during LUCA. The Bureau

estimates that over 18,000 local governments have designated a

 

42 This was practically and economically infeasible for a number of localities in

1990. David Farber, Greenacres, Florida city manager in 1990, reported “The

15-day period was just not long enough to correlate the raw data [the Census

Bureau] provided you with.” In 1993, Greenacres paid $80,000 for a special

census that found 3,283 additional residents.

“Precensus and

postcensus review of unit

counts is just as crucial in

the year 2000 count as it

was in the last decennial.”

Redding, California

Mayor David Kehoe
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liaison to work with the Bureau updating the Master Address File.43

Post-Census Local Review is a logical follow-up to those efforts,

confirming that the addresses submitted during LUCA were

counted during the census.

Since 1990, many local

governments have

developed address

databases and mapping

systems comparable or

superior to those of the

Bureau. State and local

governments have

rapidly expanded their

use of mapping and

database technology,

generically referred to as

Geographic Information Systems (GIS). GIS can provide extremely

detailed housing information, down to a house-by-house record of

addresses and their corresponding positions on a map. Two of the

country’s most advanced GIS operations, agencies of the City of

Sacramento and the State of South Carolina, took part in the

census dress rehearsals in April 1998. Representatives of

Delaware County, Ohio demonstrated comparable technology at

the November 6, 1998 Board meeting.44 These operations are

characterized by small staffs, efficient budgets, and a high level of

technical proficiency.45 Their proliferation has produced a unique

situation in the history of American census-taking: for the first time,

a growing number of local authorities actually have better mapping

technology and address information, at the local level, than the U.S.

Census Bureau.

Follow-up is especially important in light of testimony from dress

rehearsal sites in South Carolina and Sacramento, and reports that

local updates are not consistently added to the Master Address

File. This situation was exemplified during Sacramento’s dress

 

43 Department of Commerce, Office of the Inspector General, Additional Steps

Needed to Improve Local Update of Census Addresses for the 2000 Decennial

Census Inspection Report No. IPE-10756 (Washington, DC, September 1998), 7. 44 U.S. Census Monitoring Board, Public Hearing, 6 November 1998, 89-109.

45 U.S. Census Monitoring Board, Public Hearing, 5 August 1998, 83.

“During the 1995 Special

Census, our post census

local review revealed that

9,075 Scottsdale residents

were not counted by

census enumerators.”

Scottsdale, Arizona Mayor

Sam Campagna
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rehearsal, where the Department of Commerce’s Inspector General

reported “the Bureau was unable to insert all corrections to maps

resulting from the ‘Local Update of Census Addresses’ in time for

the start of the operation. Bureau geography specialists explained

that processing of updates to the map files was delayed because

while as many as four bureau teams were trying to update

Sacramento’s master map file concurrently, only one person at a

time is permitted access to the map file. As a result, geography

specialists attempting to make local updates to census address

changes were unable to access the map file; therefore, maps did

not reflect these changes.”46

These problems, echoed in correspondence to the Board from local

governments across the country (see below, and Chapter 9, “Board

Receives Feedback From Local Governments”), contradict Bureau

assertions that the LUCA program is a replacement for PostCensus Local Review. Unquestionably, LUCA is a valuable

expansion of the pre-census review. However, in the interests of

local accuracy and input to the census, local officials and national

representatives should assure the right of local review after April 1,

2000.

 

46 Department of Commerce, Office of the Inspector General, Sacramento Dress

Rehearsal Experience Suggests Changes to Improve Results of the 2000

Decennial Census Audit Report No. ESD-10784-8-0001 (Washington, DC,

September 1998), 6.

“We, as cities, need to have the opportunity,

before the census count is in cement, given to

the President, for the President’s review by the

end of the year 2000 - so we can evaluate ... and

say, ‘Here is where you are wrong, and here are

the changes we’d like for you to consider.’

 I think we ought to be given that time.”

Detroit Mayor Dennis Archer

U.S. Conference of Mayors meeting

Washington, DC, 27 January 1999.
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REASONS TO REINSTATE POST-CENSUS LOCAL REVIEW

• 1990 Post-Census Local Review revealed inaccurate counts in

need of review.

• A final quality check of Bureau data, which usually contain a

number of discrepancies, is necessary.

• An accurate count is more difficult in areas of high growth.

• Municipalities are dependent on the accuracy of the count for

federal (and often state) revenue.

“During the 1990 post-census review, the City of Fairfield

identified 1,135 dwelling units (approximately 3,400 people) that

had not been counted in the census. This undercount was

eventually corrected by the Census Bureau. If the City had not

had the opportunity to correct this undercount, the City would

have experienced revenue losses of up to $211,500 per year from

the State of California and a potential loss in Community

Development Block Grant Funds of $30,300 per year.”

George Pettygrove, Mayor, Fairfield, California

“In 1990, Elk Grove Village reviewed the Census Bureau’s

preliminary count. Village staff found that a newly constructed

subdivision had failed to be counted which included 349

residents. Furthermore, based on the per capita revenue

dispensed by the State of Illinois, Elk Grove Village would have

lost over $35,000 in annual revenue (almost $250,000 in total) had

the review process not existed.”

Craig B. Johnson, Elk Grove Village President.

“Based on our experience and the national information provided

in your letter, we feel our first comment must be to urge the

Secretary of Commerce to reconsider a very ill-advised decision.

Census 2000 is of too great a significance to cities to allow the

data to be used without our first having an opportunity to review

it.”

Kirk Humphreys, Mayor, City of Oklahoma City
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Chapter

7

In 1990, the Bureau successfully used state and local

administrative records to locate nearly half a million people in one

of the hardest-to-count populations: people on parole and

probation. Experience suggests people with a criminal record were

highly unlikely to answer a government census-taker in 1990, and

are just as unlikely to answer a government survey-taker in Census

2000.

The Parolee/Probationer Coverage Improvement Program (PPCIP)

and the Parolee/Probationer Coverage Improvement Follow-up

Program (PPCIPFU) were created to locate this hard-to-count

population. Since parolees and probationers are required to report

any address change, and are unlikely to be found through a census

or a survey, the Bureau reasoned this would be an ideal population

to locate using administrative records. Combined, the programs

added 447,757 persons to the census that would otherwise have

gone uncounted – 0.2 percent of the total 1990 population.

Also, disproportionate numbers of parolees and probationers are

members of minority populations, particularly African-American

males. The Bureau reasoned this approach would reduce the

differential undercount.47 The Bureau reported “approximately 27.1

percent of all person adds were Black males.” In 1990, African-

 

47 Susan C Wajer, Department of Commerce, Bureau of the Census, The Final

Results From the Parolee/Probationer Coverage Improvement Program and the

Parolee/Probationer Coverage Improvement Follow-up Program (Washington

DC, 1990), 1.

PAROLE/PROBATION FILES

IMPROVED LOCAL ACCURACY

“48.6 percent of all

Mississippi's eligible

parolees/probationers were

added to the census from

these programs [using

administrative records].”

Bureau of the Census
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American men made up only about six percent of the total

population. Since the proportion of “adds” was greater than the

proportion of population, the Bureau concluded, “these programs

did help to address the differential undercount.”48

Reducing Differential Undercount49

In fact, states and localities demonstrated a significant reduction in

state differential undercount. For instance, "Mississippi had a

person add rate greater than 40 percent; this state had the highest

person add rate as a percentage of its 1989 eligible parolee and

probationer population. In other words, 48.6 percent of all

Mississippi's eligible parolees/probationers were added to the

census from these programs."50 The state of Mississippi's Black

undercount, according to the Bureau was 33,990.51 Without the

5,190 persons added through the parolee/probationer programs,

Mississippi’s Black undercount would have been 15 percent

higher.52

 

48 Ibid.

49 Ibid.

50 Ibid., 11.

51 Department of Commerce, Bureau of the Census, "1990 Census of Population

and Housing Public Law 94-171 Data [Official and Adjusted] Age by Race and

Hispanic Origin" (Washington, DC, 1998).

52 Susan C Wajer, Department of Commerce, Bureau of the Census, The Final

Results From the Parolee/Probationer Coverage Improvement Program and the

3.4%

27.1%

36.2%

1.9% 5.8%

41.1%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

White Males Black Males Other Males

PPCIP/PPCIPFU 1990 Census
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Given the Bureau’s favorable assessment and the success

reducing the differential undercount, it is surprising these programs

have been eliminated from the Census 2000 operational plan.53 To

support that decision, the Bureau cites subsequent analysis of the

local files used in 1990. As the following section describes, this

analysis was flawed.

The Bureau’s Evaluation of the

1990 Parole/Probationer Program Was Flawed

In 1990, when a person was not found at an address in the census,

but was reported at that address on parole/probation records, that

person was added to the census count.

Subsequently, the Bureau compared state and local parole and

probation records to a sample of the population – the 1990 Post

Enumeration Survey (PES). This comparison estimated an

erroneous enumeration rate of 57.3 percent.54 That is, 57.3 percent

of the 447,757 parolees and probationers added to the census

were not found at the same address by the PES. For the purpose

of this comparison, the Bureau assumed the PES was accurate.55

However, in 1992, a high-ranking Bureau committee found the

1990 PES had many errors. The CAPE report concluded about 45

percent of the 1990 PES estimated undercount represented

measurement bias in the 1990 PES, not undercount in the

census.56 It is also worth noting that one of the reasons the Bureau

 

Parolee/Probationer Coverage Improvement Follow-up Program (Washington

DC, 1990), Attachment, 1.

53 “In addition, the efforts required will detract from a more pressing need to build

a consensus for the use of sampling to account for nonresponding households.”

Robert Marx, Department of Commerce, Bureau of the Census, Census2000

Decision Memorandum No. 10: Decision to Drop Plans to Use Administrative

Records to Derive the Census Count for Some Non-responding Housholds

(Washington, DC, 4 February 1997).

54 Susan C. Wajer, Department of Commerce, Bureau of the Census, Results

from the 1990 Search/Match Operation: Add Rates and Erroneous Enumeration

Rates by Search Form Type (Washington, DC, 1990), 15. 55 Ibid., 9.

56 Department of Commerce, Bureau of the Census, Committee on Adjustment of

Postcensal Estimates (CAPE Committee), Assessment of Accuracy of Adjusted
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chose to use parole and probation records was to account for a

population that actively avoids government accounting. It is logical

to assume that a person with a criminal record who avoids the

census would also avoid the PES – or any other government

statistical survey.

Clearly, the 1990 PES, full of its own inaccuracies, was inadequate

to measure the accuracy of the parolee and probationer programs.

The comparison to local records also suggests the 1990 PES was

no more effective locating the parolee and probationer population

than the census.

In addition, the National Academy of Sciences criticized a similar

comparison of administrative records to population samples during

the Bureau’s 1995 census test. “Because of the broader coverage

of the administrative files, [the Bureau’s] calculations understate the

relative frequency with which administrative records could be

matched to census records. Without an accompanying

explanation, these match rates may be misinterpreted as

evidence of poor quality in the administrative records”

[emphasis added].57

The parolee and probationer programs added nearly a half-million

real persons to the census using state and local sources. That the

Bureau has eliminated the program from Census 2000 is troubling,

especially in light of current national statistics indicating the

potential to find real persons through parole and probation records

is even greater for 2000. According to the United States

Department of Justice, in 1997 there were over 3.5 million persons

on parole and probation in the United States, more than half of

whom are African-American, Hispanic, Asian, or members of other

minority populations.58 There is still a critical need to use state and

local administrative records to help find parolees and probationers.

 

Versus Unadjusted 1990 Census Base for use in Intercensal Estimates

(Washington, DC, 7 August 1992),15

57 Preparing for the 2000 Census: Interim Report II, ed. Andrew A. White and

Keith F. Rust, by Panel to Evaluate Alternative Census Methodologies,

(Washington, DC: National Academy Press, 1997), 67.

58 Department of Justice, Bureau of Justice Statistics, “Probation and Parole

Statistics: Summary Findings,” (Washington, DC, 1998),

http://www.ojp.usdoj.gov/bjs/pandp.htm.
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STUDYING WAYS TO REDUCE

DIFFERENTIAL UNDERCOUNTS

In 1988, the Bureau hired Dr. Jerusa Wilson, professor of psychology at Coppin

State College, Maryland, to write Reducing the Undercount of Black Male

Persons and Young Black Children in the 1990 Decennial Census. In this report,

Dr. Wilson cited Bureau research indicating “blacks accounted for 53% of the

total number of persons missed in the 1980 Census.”

Dr. Wilson concluded the differential undercount resulted from certain

characteristics of a hard-to-count population, such as poverty, high

unemployment rates and low education. Dr. Wilson reported “in general, the

greater the ‘misery index’ the greater will be the census undercount for a group.

The ‘misery index’ is used here to refer to range of factors indicating low level

overall adjustments in the American society.” He observed “among the major

race-sex categories, black men are believed to have the highest rank on the

misery scale followed by black women, white men, and then white women. This

rank order holds for the census undercount.”

Dr. Wilson’s research contributed to the Bureau’s development of the parolee

and probationer programs. According to a 1990 Bureau report, “the PPCIP was

initiated as a coverage improvement program to help address the differential

undercount of Black males ... Dr. Jerusa Wilson in 1988 suggested that ‘ . . .

parolees and probationers would be highly representative of the hard-to-count

Black male group.”

Both Dr. Wilson and the Bureau based their conclusions on data regarding the

parolee and probationer populations. Based on data from a survey of federal,

state and local agencies, the Bureau concluded the 1987 “U.S. probationer

population of approximately 2.2 million persons was 72.7 percent male, 22.2

percent Black, and 51.9 percent Nonblack, with 25.9 percent not reporting race.”

Thus, the Bureau developed a targeted coverage improvement program to

attempt to find hard-to-count persons using parole and probation data.
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Chapter

8

The opportunity to correct the differential

undercount is not limited to parole and

probation records. According to the Bureau,

“children were much more likely than adults

to be undercounted in the 1990 census ...

they accounted for 52 percent of the

undercount.”59 The Bureau can find

undercounted children in 2000 using

administrative records. Several state and

local programs maintain timely, accurate

records with names and addresses. For instance Medicaid,

Temporary Assistance to Needy Families (TANF), and Food

Stamps are federal aid programs maintained locally by states and

cities, and are specifically designed to aid children. According to

officials in the District of Columbia, enrollment rates among the

District’s poorest children in minority communities top 90 percent.

People may not have time or interest enough to fill out a census

form. But no matter how busy, and no matter how economically

and educationally disadvantaged a low income mother may be, if

her child gets sick, that mother knows how to get her child to a

doctor. In Washington D.C. and elsewhere, that child must be

enrolled in Medicaid to see a doctor.

For example, local Medicaid files could be especially useful in

reducing the differential undercount of children in the District of

Columbia’s eighth voting precinct. Ward 8 is a predominantly

Black, low-income voting precinct just minutes southeast of the

nation’s Capitol. The Bureau estimates the 1990 census missed

more than 1,800 children in Ward 8.60 In May 1998, District officials

listed the name and address of nearly 12,000 child Medicaid

recipients in Ward 8.

 

59 Department of Commerce, Bureau of the Census, Report to Congress – The

Plan for Census 2000 (Washington, DC, August 1997), 3. 60 Department of Commerce, Bureau of the Census, “1990 Census of Population

and Housing Public Law 94-171 Data [Official and Adjusted] Age by Race and

Hispanic Origin” (Washington, DC, 1998).

ADMINISTRATIVE RECORDS CAN

IMPROVE LOCAL ACCURACY

Over 18.5

million

children

were

enrolled in

Medicaid in

1997.
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The Bureau could use those records to locate children most likely

to be missed in the census in Ward 8. Adding people to the census

using Medicaid or similar records is more accurate than adding

people through statistical adjustment, which would increase,

erroneously, minority population counts in Ward 3 – an

overwhelmingly non-Black and non-Latino area.

High undercount areas are

not randomly distributed.

Instead, undercounted

blocks tend to cluster in

neighborhoods and larger

areas such as Ward 8. The

way to reduce both racial

and area population

coverage differentials, then,

is to concentrate on those

relatively few geographic

areas with higher undercount

rates.

The Bureau’s research has

identified specific areas that were hard-to-enumerate in 1990, and

probably will be again in 2000. A Bureau report indicates that most

of the census undercount tends to be clustered in relatively few

geographic areas. The Bureau anticipates that fully one third of the

hardest-to-count census tracts in 2000 will be located in just three

cities: New York, Chicago and Los Angeles.

The Bureau reports that almost half of the hardest-to-count census

tracts in the country are located in just 11 cities. Those hard-tocount tracts in those 11 cities represent a mere two percent of all

the census tracts in the country. The Bureau concludes that,

“These data demonstrate that [hard-to-count] tracts are very

concentrated geographically and can be targeted.”61 Sensible

efforts to find undercounted populations will target these hard-tocount areas.

 

61 J. Gregory Robinson and Antonio Bruce, Department of Commerce, Bureau of

the Census, The Planning Database: Description and Examples of its Targeting

Capability (Washington, DC 18 September 1998 (revised 5 October 1998)), 7.

Almost half of the

hardest-to-count census

tracts in the country are

located in just 11 cities.

New York Chicago

Los Angeles Detroit

Houston Cleveland

Milwaukee Newark

Miami Dallas

New Orleans
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Administrative records can locate people in very specific

geographic areas. This approach would concentrate work in the

areas where the administrative record sources indicate the largest

potential undercounts in the census.

Consider the example of Ward 8 Medicaid files. The files are

updated monthly and are computerized. After all non-response

follow-up is completed, the Bureau could review the January 2000

Medicaid files, begin matching, and identify people from Ward 8

enrolled in Medicaid but absent in the census. (Matching records

statewide or nationally, high undercount areas like Ward 8 will show

up as areas with more unmatched Medicaid cases.)

The Bureau could then double-check using April’s Medicaid files. If

Medicaid shows someone living at an address in Ward 8 in both

January and April, whom the census has not found, add that person

to the census at that address. Unmatched persons who have

moved could be added to the census at their April address.

The vast majority of this work can be done rapidly and accurately

using the Bureau’s matching software. Records can be sorted by

geographic areas to work from areas with the most nonmatches, to

areas with fewest nonmatches.

Double-checking two sets of Medicaid files answers one of the

most significant concerns of the census, noted by Director Prewitt

and others: validating occupancy on April 1, 2000, Census Day.

This approach might be implemented with less error than any

proposed statistical adjustment. Administrative records offer fewer

opportunities for failure. The work flow plan for the statistical

adjustment the Bureau intended before January 25 was

characterized by separate steps, hand-offs, and a tight timeframe.

As outlined above, an administrative records approach can involve

a much simpler set of tasks and fewer points of potential failure.

After all, the statistical adjustment plan (rejected by the Supreme

Court) proposed five times the workload, performed in roughly the

same amount of time, as the 1990 PES. Using administrative

records is more consistent with the Census Bureau strategy to

“Keep it Simple.”
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Use Federal Records to Find Children

in Hard-to-Enumerate Areas, Nationally

A number of federal programs are specifically designed to reach

and serve children. Their records could be used to reduce the

general undercount of children, and the differential undercount of

many children in urban and rural areas. Potential sources include

Medicaid, Temporary Assistance to Needy Families (TANF) and

Food Stamps.

According to the Healthcare Financing Administration, Medicaid’s

administrator, over 18.5 million children were enrolled in Medicaid

in 1997.62 Of those programs that distribute aid using census

numbers, Medicaid distributed the most funding (more than $100

billion) in 1998.63

TANF, formerly known as Aid to Families with Dependent Children

(AFDC), was created in 1996 as part of national welfare reform.64

In March 1998, the Office of Family Assistance reported over 3

million families receiving TANF.65 Approximately 60 percent of

these families are minorities, Black and Hispanic.66

The Food Stamp program also serves children and families. The

Department of Agriculture indicates that in August 1997, there were

over 20 million participants in the Food Stamp program,67 and “60

percent of food stamp households include children.”68 Each of

 

62 Department of Health and Humans Services, Health Care Financing

Administration, HCFA-2082 Report (Washington, DC: Health Care Financing

Administration, 20 October 1998), Table 28.

63 General Accounting Office, General Government Division, Decennial Census –

Overview of Historical Issues, GAO/GGD-97-142, July 1997, 14. 64 Department of Health and Human Services, Office of Family Assistance,

(Washington, DC, 7 October 1998), http://www.acf.dhhs.gov/programs/ofa/.

65 Department of Health and Human Services, Office of Family Assistance,

Change in Welfare Caseloads: As of June 1998 (Washington, DC, 1998). 66 Office of Family Assistance, Temporary Assistance to Needy Families (TANF):

First Annual Report to Congress (Washington, DC: Department of Health and

Human Services, Office of Family Assistance, August 1998), Section VII,

Demographic and Financial Characteristics.

67 Department of Agriculture, Food Stamp Program, “Some Food Stamp Facts”

(Washington, DC, 1998), http://www.usda.gov/fcs/stamps/fsfacts.htm. 68 Department of Agriculture, Food Stamp Program, “Nutrition Program Facts:

Food Stamp Program” (Washington, DC, 1998),

http://www.usda.gov/fcs/stamps/fspfor~1.htm.
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these programs reaches a number of the nation’s poorest children

— the same children likely to be missed by either census plan.

To maintain these programs, local governments are required to

keep current accounting files. For instance, the City of Chicago's

Housing Authority keeps public housing records. In Robert Taylor

Homes, one of the hardest-to-count neighborhoods in the country,

the Housing Authority lists addresses for over 6,300 residents, 83

percent of the total residency, who received SSI, AFDC or TANF

benefits in September 1998. More importantly, 66 percent of the

residents receiving aid were children of minority families.

Federal law in 1996 changed reporting requirements for several

agencies providing medical care, financial assistance, and food for

millions of children and families who reside in the same areas the

census is likely to undercount in 2000. HCFA, for instance, created

the Medicaid Statistical Information System (MSIS), to “collect,

manage, analyze and distribute information on eligible recipients.”69

In fact, the MSIS files will represent a complete snapshot of

Medicaid participation. There will be “one record for each person

who was eligible for Medicaid for at least one day”70 in the local files

and the MSIS files.

It is important to note that, “in accordance with the Balanced

Budget Act of 1997, all claims processed on or after January 1,

1999, must be submitted electronically in the MSIS format.”71 In

other words, Medicaid records kept by state and local governments

will be not only current, but also generally uniform. Most

importantly for census purposes, some demographic information

will be common for all person records, including: date of birth, date

 

69 Health Care Financing Administration, “Health Care Financing Administration

Medical Statistical Information System (MSIS) Project Overview” (Washington,

DC, 6 July 1998), 2.

70 Ibid.

71 Department of Health and Human Services, Health Care Financing

Administration, “HCFA 2082 Reporting Through the Medicaid Statistical

Information System (MSIS)” (Washington, DC, 15 September 1998),

http://www.hcfa.gov/medicaid/m2082.htm.
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of death, sex, race, county code, ZIP code, personal identifiers, and

social security number.72

The potential to find specific missing children, placing the individual

child where he or she lives and reducing the differential undercount

in his or her neighborhood using local records, is worth pursuing.

The Congressional Members of the Board are troubled by the

decision to terminate coverage improvement programs that

contributed to the addition of one million people, most of whom

were from minority communities or urban areas, from the 2000

plan. Such a decision seems to invite failure. Relying solely on the

Department of Commerce’s untested statistical adjustment, with no

contingencies to address what Congress and the Administration

agree is the most important challenge of Census 2000, is

unconscionable.

 

72 Department of Health and Human Services, Healthcare Financing

Administration, “Health Care Financing Administration Medicaid Statistical

Information System (MSIS) Project Overview,” 5.
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ADMINISTRATIVE RECORDS ARE MORE ACCURATE THAN

STATISTICAL ADJUSTMENTS TO REDUCE DIFFERENTIAL

UNDERCOUNTS

In order to benefit historically undercounted groups, the census must reduce

racial and ethnic differential undercounts among local geographic areas. The

census must answer two questions: “How many people are there?” and, “Where

are they?” Answering the first without answering the second is insufficient.

This is why. Political power and money are distributed according to geographic

or political areas – not demographic groups. If the census determines how many

minorities live in a state, but not how many live on a city block, the people in that

block still won’t receive a fair share of representation or revenue. Since

administrative records can add specific people to specific blocks, they have a

greater potential to reduce the racial, ethnic and geographic population coverage

differentials than any statistical adjustment. Statistical adjustment might answer,

“How many?” However, it can’t accurately answer, “Where?”

One reason is that undercounts are spread unevenly over geographic areas,

while statistical adjustments tend to be spread evenly over geographic areas.

That is, for many small geographic areas the undercount is minimal or

nonexistent, or there may even be an overcount. Other areas have large

undercount errors, say on the order of 20 percent. Between these two extremes

are some areas with moderate undercounts.

The Census Bureau’s plan to use statistical adjustment does not adequately

focus on specific areas. Instead of locating people, statistical adjustments

relocate people. Adjusting the census by a post-enumeration survey takes a

concentrated population and dilutes it throughout a state, until a specific

community of common race, income and location is spread across several

communities that share similar characteristics.

By way of illustration, consider the following simplified situation. Assume there

are ten geographic areas of equal population comprised of members of one

single post-strata, such as black males in rental housing. Further assume that

nine of these areas have zero (or close to zero) undercount and the tenth area

has a 20 percent undercount. Obviously, the tenth area is of greatest concern to

the census.

Now assume the statistical survey estimates the undercount for these combined

areas is 2 percent. If the undercount is distributed by the Bureau’s statistical

method, each of the nine accurately-counted areas is increased by 2 percent,

resulting in 102 percent of actual population. The tenth area is also increased by

2 percent, reaching only about 82 percent of its actual count.

Little is done to minimize coverage differentials among geographic areas. While

the population total for the ten areas is accurate, the people in the undercounted

tenth area remain unidentified, underserved and underrepresented.
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Section

9

The Congressional Members of the Board have aggressively

pursued information from federal entities already engaged in

oversight and local governments participating in the Census 2000

dress rehearsals and the pre-census address list review program,

LUCA.

Beginning on June 3, the Board met on six occasions in 1998. Two

of those meetings were held in Washington, DC. Two were held at

Census Bureau headquarters in Suitland, Maryland. The Board

also met at dress rehearsal sites in California and South Carolina,

hearing testimony from Bureau employees, local officials and

community leaders. In addition,

Congressional Board staff twice

visited the Menominee Reservation

dress rehearsal site, the second time

in the company of Presidential Board

Member Lorraine Green and staff.

Congressional Board Members and

staff (along with Presidential Board

staff) met with Bureau senior staff on

eight occasions for general briefings

on various aspects of decennial

census research, planning and

operations. Briefings generally lasted

two hours. Topics included

Administrative Records, contracts with outside vendors, the

Integrated Coverage Measurement (ICM), the Local Update of

Census Addresses (LUCA), and paid advertising. Additional

briefings were conducted by the Department of Commerce’s

Inspector General and staff and the General Accounting Office

staff, covering many of the same topics.

After hearing testimony from community leaders and local officials

frustrated with the dress rehearsal experience in South Carolina,

the Congressional Board Members intensified efforts to build

dialogue with those who will rely on the census results for federal

BOARD RECEIVES FEEDBACK

FROM LOCAL GOVERNMENTS

A final qualitycontrol mechanism

is essential to

make certain that

recommendations

and changes

suggested by local

governments

during LUCA are

incorporated into

the census.
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(and, often, state) funding through the first decade of the next

millennium. Letters and local government conferences afforded

opportunities for dialogue.

Over 6,000 letters were sent to mayors, governors, state

legislators, county officials, township trustees, city and regional

directors and other stakeholders across the country in the latter half

of 1998. The Congressional Members of the Board inquired

specifically as to the nature and extent of local involvement with the

Bureau to date, the ability and success of local governments to

update the Bureau’s address file, and what concerns, if any, local

governments had about the Bureau’s decision to eliminate the local

review of census numbers.

Similar questions were asked at a dozen conferences of cities,

towns and local officials in 1998. Conferences included meetings

of the National Association of Towns and Townships, the Texas

and California Municipal Leagues, and the National League of

Cities and the Council of State Governments. Congressional Board

Members addressed meetings of the American Legislative

Exchange Council in August, and the National League of Cities and

the National Council of State Legislators in December. The

congressional Executive Director and staff participated in

roundtable discussions at the September meeting of the National

Association of Towns and Townships.

Feedback from these efforts falls broadly into two categories. Post

Census Local Review should be reinstated, and LUCA is a positive

improvement, but it is not enough. A final quality-control

mechanism is essential to make certain that recommendations and

changes suggested by local governments during LUCA are

incorporated into the census.

Examples of comments concerning Post-Census Local Review are

listed in Chapter Six. Examples of comments concerning LUCA

end this report.
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CONCERNS WITH LUCA

• The Bureau’s timetable requires manpower and/or financial

resources which many smaller municipalities do not have.

• Cities and counties with sophisticated GIS systems are

penalized because they have outpaced the Bureau’s

technological capabilities.

• Personnel changes, program changes and lack of information

on the part of the Bureau have frustrated many municipalities

and counties who are participating in LUCA.

“Our initial experience with the Local Update of Census

Addresses (LUCA) program has not been promising. We are

finding that the maps furnished to us by the Census Bureau are

not consistent with our locally drawn maps in relationship to the

placement of existing streets and the incorporation of data that

was previously furnished to the bureau . ... I would say that the

City of Atlanta strongly supports a post-census review program

that is fair and gives local governments adequate opportunities

to correct mistakes.”

John W. Heath, Atlanta Census Coordinator

“I am very frustrated over the procedures our County has to

follow in updating our local addresses for the 2000 Census.

Specifically, we are required to manually update all the census

maps and then make the appropriate changes on the computer

data base file. A few years ago, this would have been an

appropriate approach for this task, but our County now has a

complete, up-to-date, and accurate GIS program.”

Fran Sutton-Berardi, Senior Planner, Stanislaus County, California

“We appreciate the opportunity to review and update the

Bureau’s master address list and maps to ensure that the

enumeration is as comprehensive and accurate as possible.

However, we feel that it is equally important that local

jurisdictions be allowed to review and, if necessary, challenge

the results of the enumeration before the counts are made

final.”

Frank C. Roberts, Mayor, City of Lancaster, California

“If this LUCA process is our only means of input to ensure an

accurate count, then it is an inadequate process and does not

provide ample opportunity for feedback from the local level.”

Ross Elliot, Special Projects Manager, Kern County, California