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1 Initial Proposals for Updating OMB's Race and Ethnicity Statistical Standards (62 FR 58723) 1 (2023)

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Officers                 April 27, 2023                                              ke   e
Chair                                                                             Cn~ac
Judith L Lichtman
National Partnership for
Vie& Famih              The Honorable   Richard  L. Revesz
Mdargaret HuangAdistao
Southern Povey Law Center Administrator
DNCk hfon              Office of Information  and Regulatory  Affairs
Thomas A. Saenz
Mexican American Legal   Office of Management and Budget
Deense and Educational Fund
S                        1800  G Street, NW,  9th Floor
Fatima Goss Graves
National Woman's Law Center  Washington, DC 20503
Treasurer
Lee A. Saunders
American Federation of State,
County and Municipal Employees  Submitted via e-mail: mbx.omoirastatistical directives@ombeo  ov and at

  Abe Ayoub      wwwyregulations, 2ov
Aoad Ao irctr
American-Arab
Anti-Discrimination Committee
GloL Blackwell           Re: Initial Proposals  For  Updating   OMB's   Race  and  Ethnicity  Statistical Standards   (62

Inturnaticnal Union, UAW FR  58723)
Jocelyn Frye
National Partnership for
'Women & Families
Jonathan Greenblatt      Dear Administrator   Revesz:
Anti-Defamation League
Mary Kay Henry
Service Employees International Union
Damon HevAtt             On  behalf of The Leadership  Conference   on Civil and Human   Rights, a coalition charged  by
Lawyers Committee for
Civil Rights Under Law   its diverse membership  of more  than 230  national organizations to promote  and protect the
David H. Inoue
Japanese American Citizens League  civil and human rights of all persons in the United States, and the undersigned organizations,
Virginia Kase Solomon
League °f Women Voters of the  we appreciate this opportunity to provide comments in response to Initial Proposals For
United States
Marc Morial              Updating  OMB's   Race  and Ethnicity Statistical Standards  from the Federal Interagency
National Urban League
    Mumma           Working Group on Race and Ethnicity Standards (working group) published in the Federal
 Un iosU S
 Sv n the AmericMy  wiy  Register on January  27, 2023  (the notice). The Office of Information  and Regulatory

   C Legal Defenseand    Affairs (OIRA)  has tasked  the working  group with  developing  recommendations for   revising
 Educationdln         0MB Directive 15: Standards for Maintaining, Collecting, and Presenting Federal Data on
 Christan F. NunesO          BDrcie1:SadrsfrMitiigCletnadPeetn                                         eea      aao
 Nationa Organization for Women Race and Ethnicity (standards). The organizations submitting these comments commend
 Rabbi Jonah Psser        aeadEhiiy(sadrd.Teognztossbitigteecmet                                            omn
 o     smAt'o           OMB   and  OIRA   for recognizing that continued racial and ethnic change  in the United States
 Natioal Education Association  requires an evolution in the statistical policy governing how we measure the demographic
 Lisa Rice
 National Fair Housing Alliance composition of our population.
 Kelley Robinson
 Human Rights Campaign
Anmerican Ci Liberties Union  The Leadership Conference is the nation's oldest, largest, and most diverse civil and human
Liz Shuler
AFL-CIO                  rights coalition and provides a powerful  unified voice for the many  constituencies we
Fawn Sharp
National CongressofAmerican Indians  represent. Our coalition views an accurate and fair census, and the collection of useful,
Maria Town
American Association of  objective data about our nation's people, housing,  economy,   and communities   generally, to
People with Disabilities
RandiWeingarten          be among  the most  important  civil rights issues of our day.
American Federation of Teachers
John C. Yang
Asian Americans Advancing JusticeI
AAJC                     To that end, The Leadership   Conference  has served  as a Census Information  Center  for

President and CEO        nearly two decades,  a role that has allowed us to lift up within our broad civil rights coalition
Mava Wiley               the fundamental  importance  of comprehensive,   high-quality data about  our population,

                         communities,  and  economy.  We   also have a long history of first-hand experience working   in
                         support of previous censuses  and  in support of the Census Bureau's  American   Community
                         Survey  (ACS).  Our Census   Task Force  meets regularly to keep  stakeholders informed  about

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