February 5, 2002

Ms. Madeleine Clayton

Departmental Paperwork Clearance Officer

Department of Commerce

Room 6086

14th and Constitution Avenue, NW

Washington, DC 20230

Re: The American Community Survey: Proposed Collection; Comment Request

Dear Ms. Clayton:

As requested in the Federal Register : January 16, 2002 (volume 67, number 11), I am submitting my comments on the proposed data collection method for the American Community Survey (ASC). I am Deputy Director for Transportation Planning at the Delaware Valley Regional Planning Commission (DVRPC) in Philadelphia, Pennsylvania. I have a Masters Degree in Urban Planning from Michigan State University and a Ph.D. in City and Regional Planning from the University of Pennsylvania. DVRPC is a bi-state planning commission for the Delaware Valley region which includes an area of more than 3,800 square miles in Pennsylvania and New Jersey and a population of about 5.4 million. For airport system planning, the DVRPC region extends to two counties in the states of Delaware and Maryland.

DVRPC depends on census data for land use and transportation planning. Most of the data we use comes from responses to the long form of the decennial census. This information is included in the Census Transportation Planning Package (CTPP), which is prepared by the Census Bureau after each decennial census. This is the most efficient way to obtain the data we need at the Traffic Analysis Zone (TAZ) level. We use census data for almost all regional planning projects, such as the following:

1.	Development of a database for transportation planning, strategic planning and economic development at the TAZ level.

2.	Analysis of land use and travel trends during the last 30 years.

3.	Update of travel simulation and forecasting models.

4.	Analysis of transportation facilities improvements and their impacts on air-quality to demonstrate the conformity of transportation plans and programs.

5.	Development of a complete data file for workers and employment at the TAZ level.

6.	Provision of census data to public agencies and private companies, especially the journey-to-work information by travel mode and other socioeconomic data at the TAZ level.

Accurate data at the TAZ level are vital for our planning projects. Before we use census data, we review them to make sure they are tabulated and allocated correctly to municipalities and TAZs. We have 352 municipalities and more than 1,900 TAZs in the region. Our evaluation of the 1990 CTPP has shown that the margin of error in the decennial census data is relatively small and consequently are adequate for our planning projects. DVRPC cannot afford to spend millions of dollars on collecting such data which is provided by the Census Bureau at no cost.

In 1994, I heard the first presentation about the ACS (Continuous Measurement) and was happy to learn that we would obtain updated data annually for the years between the decennial censuses. Also, I heard that the proposed ACS will result in quality data at the census tract level and reduce the cost of data collection and processing. Furthermore, the Census Bureau will not remove the long form from the decennial census until the ACS results and data are evaluated for accuracy, completeness, and cost. Now I hear from my colleagues at the Census Bureau and transportation planners throughout the country that "The death knell is sounding for the long form." Apparently, the Census Bureau has decided to replace the long form in 2010 with the ACS. I think abandoning the long form from the 2010 Census before a thorough evaluation of the ACS program and results are complete is a fatal mistake.

Under "I. Abstract" of the proposed data collection, the Census Bureau claims that the ACS "will allow the Census Bureau to remove the long form from the 2010 Census, thus reducing operational risks, improving accuracy, and providing more relevant data." Such a statement is not supported by any facts. Under "II. Method of Collection," the Census Bureau will mail questionnaires to a small sample of households (250,000 per month). For those who do not return the questionnaire, Census Bureau staff will attempt to conduct interviews using computer-assisted telephone interviewing (CATI). In addition, the Census field representatives will use computer-assisted personal interviewing (CAPI) for reinterviewing some respondents and provide telephone questionnaire assistance. This method is typical of household travel surveys around the country, which are usually completed in one year, not over many years (2002-2008) as proposed.

Under "III. Data," the Census Bureau plans to contact 9,105,000 households, 40,000 persons in group quarters, and 81,000 households for reinterview during the period of November 2002 through October 2005. This sample size is less than one half of the sample selected for the decennial census. Apparently, although not mentioned, this is the first part of the ACS program because it is stated under "I. Abstract" that the ACS must begin full implementation in 2003 to provide comparable data at the census tract level by July 2008. It appears that the second part of the ACS will be requested in the future for the period 2005 to 2008. The sample size and cost of the second survey period should be known at this time to decision makers in the federal government and Congress. Also under "III. Data" they propose mandatory obligation of respondents. This is an additional burden on households, not appreciated by the majority of the population.

Based on my 30-year experience with census data and household surveys, the proposed plans to conduct the ACS during 2003 - 2005 will not be as successful as the decennial census because of the following:

1.	The response rate to the ACS will be smaller than the census. Based on our 2000 household travel survey, the response rate to the ACS will be less than 60 percent of the census response rate. Also, the household responses will be biased since the proposed sample of nonrespondents is too small (81,000) to represent the total population.

2.	The quality of the collected data at the TAZ level will be compromised since the sample size is reduced for the 2003 to 2005 survey period and the ACS estimates will be an average over three year period. This estimation method (continuous measurement) increases the sampling errors significantly, especially in such data as the journey-to-work information. Updating the 3 or 6 year average annually, as proposed, will result in at least 25 percent sampling errors in the annual estimates compared to the long form, as calculated correctly by the Census Bureau. The sample error in the ACS estimates will have an additional error resulting from expanding the sample to the universe based on "current population estimates" rather than the 2000 Census. Thus, the error in the ACS estimates will multiply from one year to another because the ACS estimates are based on current population estimates and the proposed sample is too small to represent respondents and nonrespondents.

3.	To obtain reliable data from the ACS comparable to the census, the cost would be similar to the census. In its comments on the General Accounting Office draft document entitled: 2000 Census: Significant Increase in Cost Per Housing Unit Compared to 1990 Census, the Census Bureau states correctly that the "Census 2000 was enormously successful," and the increase in cost was due to producing high quality data. The increase in cost was due, among other things, to increases in the cost of enhanced methods for data content and products, extensive marketing, communication and partnership programs. None of these successful programs are proposed for the ACS under "II. Method of Collection."

To meet the needs of data users, I suggest that the Census Bureau increase the sample size of ACS from 9,105,000 to at least 13,000,000 households (approximately two thirds of the sample size of the decennial census, and conduct the entire survey in one year (2006) rather than annually over three years. To obtain quality data from the ACS, the Census Bureau should develop comprehensive marketing, communication, and partnership programs based on the 2000 Census experience. There is no need to update census data annually. We would be very happy if the Census Bureau provides us with accurate zonal data for one year in the middle of the decade comparable to the results of the 2000 Census.

In summary, the notice of the proposed collection for the ACS dated January 16, 2002 is incomplete and confusing. The ACS data will not be as accurate as the decennial census and the information will not have practical utility. A thorough evaluation of the cost and results of the ACS at the TAZ level should be conducted before removing the long form from the 2010 Census. The ACS should not be viewed as a substitute for the long form of the 2010 Census. Like the current population estimates program, the ACS should be conducted to update the data between decennial censuses. Contrary to the views of some officials, the increase in the decennial census cost is not due to the long form since more than 83 percent of households receive the short form. According to the 2000 census experience, the increase in cost was due to many successful programs such as extensive marketing, communication, partnership, enhanced methods for data contents and products, field data collection, and use of technological innovations in data collection. These economy of scale programs were needed to obtain better responses and quality data from all households whether they received long or short forms.

Thank you for the opportunity to comment on this important survey.

Very truly yours,

Thabet Zakaria, Ph.D

Deputy Director

Transportation Division

TZ:ms

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