Comment from the AfroLatino Coalition on Proposed Census Race/Ethnicity Coding List
Concerns Regarding the 2030 Census Race and Ethnicity Data Collection and Tabulation Methodology
We are writing to express our deep concern regarding the current proposal for collecting and tabulating race and ethnicity data in the annual American Community Survey (ACS), the 2030 Census and other federal data collection. Specifically, the current proposal will inaccurately categorize Black Latino individuals, erasing their unique social and economic statuses and identities and hindering efforts to address racial and ethnic inequities in health, employment, education, housing, among other social outcomes. We hope that an ethic of “do no harm” is a baseline normative principle for collecting, coding and tabulating data, and all other decision making that has potential unintended consequences on marginalized communities. The Census Bureau’s current proposal is troubling with respect to its 1) coding methodology and 2) its code list treatment of Latino ethnic and race identities.
CODING METHODOLOGY CONCERN
One of our concerns is that Black Latinos may be recoded and incorrectly categorized as “multiracial or multiethnic”. Recent evidence highlights a troubling trend at the Census of misclassifying Black Latino individuals who affirmatively assert their race as solely Black as "Multiracial." This is because the Census may inaccurately treat any "Latino" ethnic origins printed under Black as some other race and incorrectly count many Black Latinos who choose to mark one checkbox among those who report "Two or more races."This misclassification has significant consequences, as it obscures the distinct experiences with anti-Black discrimination and obfuscates the housing, employment, and health inequalities experienced by Black Latino communities. Misclassification impairs the purpose of having reliable census data to enforce civil rights laws and policies as it pertains to Black Latinos.
It is of primary importance for all Census Bureau coding decisions and actions to be guided by the Census Bureau’s ethical mandate to refrain from violating a respondent’s autonomy by coding their identity as something other than what they chose.
Accordingly, it is paramount that the Census Bureau:
Limit Autocoding to the Some Other Race (SOR) category:
Autocoding reclassification should only be used when a respondent utilizes the "Some other race" write-in category, and OMB requires that their response be retroactively fit into one of the major categories for civil rights enforcement purposes.
Autocoding should not be used to reclassify individuals as effectively “multiracial or multiethnic” with the multicode designation when that person affirmatively selects a single major race category and within that single major race category writes in an ethnicity, whether single or multicode.
For example, when a respondent affirmatively selects "Black or African American" as their single major category, and writes in a "Hispanic or Latino" nationality or cultural heritage within that single major category, their single major category selection of Black should be honored and not reclassified as an additional major category or multiracial response . Any other major categories associated with the terms printed in the write-in box should instead be recorded with a statistical flag (see below).
Utilize Statistical Flagging for Maintaining the Integrity of Self-Reported Identity:
Implement a system or series of variables , one for each major category, that flag instances where respondents select a major category and also provide a write-in within that major category that falls under the code list for a category other than the one they affirmatively selected.
For example, a Hispanic/Latino Flag variable could be used to flag when a respondent affirmatively selects "Black or African American" as their single major category, and writes in a "Hispanic or Latino" nationality or cultural heritage within that single major category.
With a flagging system, full counts for any minimum category or combination of interest could be easily achieved by combining people who affirmatively mark and those who are flagged based on a write-in response. Tabulation categories for the combined Multicode Multiethnic and/or Multiracial approach, which requires mutually exclusive categories, should only reflect what individuals affirmatively mark to maintain the integrity of self-reported identity.
Statistically flagging write-in origin(s) rather than treating it as a second race will allow for both accurate counts within major minimum categories and the collection of disaggregated data that reflects the nuanced identities of individuals.
These flags should be included in both public and micro data.
Provide Transparency in all Coding Decisions:
Appropriate government and public use of census data requires that all coding decisions be transparent and accessible. Without a disclosure of how autocoding decisions are made and who is impacted, public policies that rely upon making comparative analyses are impaired.
CODE LIST CONCERNS
The Census Bureau proposed Code List utilizes an inaccurate interpretation of the OMB’s definitions of the major categories, and as a result provides an incoherent and inconsistent approach to racial and ethnic identities that is not supported by the preponderance of scientific research and evidence.
Inaccurate Interpretation of OMB Definitions
While the OMB defines Black as a person with “origins in any of the Black racial groups of Africa,” the Census Bureau excludes AfroLatino origins in Africa, despite the fact that the vast majority of the Africans enslaved and brought to the Americas were brought to Latin America and the Caribbean.
Just as the U.S. historical legacy of slavery created a population with “origins in any of the Black racial groups of Africa," the much more extensive Latin American and Caribbean historical legacy of slavery also created populations with “origins in any of the Black racial groups of Africa." As such, those who identify as AfroLatino have a Black racial identity. Affirmatively selecting Black and identifying as AfroLatino via the origin write-in box should not exclude them from the Blackness they claim via an imposed (rather than affirmatively selected) multicode multiracial identification.
Similarly, while the OMB defines a White person as one with “origins in any of the original peoples of Europe,” the Census Bureau inaccurately excludes the European nation of Spain and all its descendants across Latin America and the Caribbean. The Spanish empire played a significant role in the European colonization project based on ideas of White supremacy. As such those who are White in Latin America and the Caribbean, are no less White than descendants of other European colonizers. Consequently it is illogical for the Census Bureau to exclude Latinos who racially identify as White from the coding list for White.
Contradictory Conflation of Nationality and Linguistic Difference with Racial Identity
The logic of linking nationalities to racial statuses does not hold. Nations are not races. Speaking Spanish does not alter one’s racial status, appearance or identity. Language and race are not concordant. Excluding the Iberian nation of Spain from whiteness because it is Spanish speaking is inconsistent with the treatment of its Iberian neighbor Portugal as a White nation simply because it is Portuguese speaking. Geography, history and logic dictate that “Spaniard” presently under code 2400-2409, and its related geography codes of 2410-2489, along with “Spanish” under code 2630-2639 should all be moved to the White code 1000-1999.
The contradictory conflation of linguistic difference with racial identity also surfaces in the proposed treatment of AfroLatino as multicode, when in contrast Afrodescendiente and Negro are allowed to be Black alone. When Spanish language terms are considered, they should be examined within the social contexts in which they are used. Black descendants with Latin American and Caribbean origins may vary in their choice of terminology, but whether the chosen term is AfroLatino, Afrodescendiente, Cocolo or Negro, each are claims of a single racial identity as Black within the racially heterogenous ethnic group of Latinos. Thus “AfroLatino” should be moved out of multicode and instead moved to Black code 3000-3999, where Afrodesendiente 3017 and Negro 3025 are already located.
Additional examples underscore why Spanish language terms should be examined within the social contexts in which they are used. "Mulato," a Spanish language word, is not equivalent to the English language term of Mulatto, nor to the contemporary U.S. term of Multiracial. Indeed, those who identify as multiracial affirmatively reject the term of Mulatto as an historical anachronism that is now pejorative. However the Census Bureau proposed code list misunderstands these important distinctions with the coding proposal to treat “Mulato” under code 8550-8559 as a White and Black multiracial multicode, thus erasing the term from its Latino Spanish language origins. The “Mulato” multicode should also include Latino as a classification along with White and Black.
Finally, the Spanish term “Quisqueya” is excluded from the proposed code list despite the fact that many Dominicans use it to identify their Dominican ethnic identity. “Quisqueya” as well as “Quisqueyana/o” should thus be added to the Hispanic code 2000-2999.
Further research is needed to resolve discrepancies in racial and ethnic coding. Several coding options warrant consideration, particularly regarding individuals of Brazilian, Belizean, Garifuna, Blaxican, and Dominican Indio descent. There are indicators in the published literature that Brazilians and Belizeans identify as Latino, that Garifuna and Blaxican identify racially solely as Black, and that some Dominicans use “Indio” as a euphemism for Black. The proposed coding list does not accord with this growing research. Further investigation and refinement of coding practices are necessary to ensure accurate representation of both the overall Latino/Hispanic and Black populations.
Coding Inconsistencies Underscore the Necessity of using Statistical Flagging and Autocoding Transparency
CONCLUSION
Accurate and ethical data collection is crucial for understanding and addressing the unique needs and challenges faced by Black Latino communities. We believe that the proposed changes in coding will have a significant negative impact on the accuracy and utility of the American Community Survey, Current Population Survey, 2030 Census data, among other federal data sets. We urge the Census Bureau to carefully consider these concerns and work with scholars and community stakeholders to develop a data collection and tabulation methodology that accurately reflects the diverse racial and ethnic identities and social statuses of all people living in the United States.
The proposed 2030 Census methodology, by potentially misclassifying Black Latinos as "multiracial or multiethnic," risks erasing their unique experiences with anti-Black discrimination and obscuring disparities in critical social outcomes. To rectify this, the Census Bureau must: 1) restrict autocoding to the "Some Other Race" category; 2) employ statistical flagging to preserve self-identified identities; 3) ensure transparency in coding decisions; and 4) revise its code list to accurately reflect OMB definitions and the lived realities of diverse Latino sub-groups, including Afro-Latinos and the racial diversity within the Latino/Hispanic population. These recommendations are essential for ensuring data accuracy, respecting self-identification, and enabling effective enforcement of civil rights protections. Ultimately, accurate and ethical data collection is paramount for understanding and addressing the unique needs of all communities, including the often-marginalized Black Latino population.
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