December 19, 2023

Submitted via www.regulations.gov

Census Bureau, Department of Commerce

1401 Constitution Ave NW

Washington, DC 20230

RE: Proposed changes to Disability Census Questions | Docket Number: 2023-23249

Dear US Census Bureau,

Subject: Comments on Proposed Changes to American Community Survey, Including PRCS

The Partnership for Inclusive Disaster Strategies (The Partnership) is the only U.S. disability-led organization with a focused mission of equity for people with disabilities and people with access and functional needs throughout all planning, programs, services and procedures before, during, and after disasters and emergencies.

We are writing to express concerns regarding the proposed changes to the American Community Survey (ACS) and the Puerto Rico Community Survey (PRCS) and their potential negative implications, particularly in the areas of emergency preparedness and response as well as inaccurate representation of people with disabilities.

The shift from the ACS’s and PRCS’s current methodology to the Washington Group Short Set is highly problematic. This change is expected to reduce the reported percentage of people with disabilities by about 40%, according to the 2022 American Community Survey Content Test Evaluation Report: Disability, omitting millions of people from the disability count. Such a drastic reduction would not only misrepresent the scale of the Disability Community but would also skew public perception and impact policy development. The lowered reported percentage of disabled people will likely lead to a decrease in the allocation of necessary services, funding, and support, which will adversely affect numerous programs, including Medicaid, education, and housing. This underrepresentation isn’t in alignment with the principles of equity and inclusion and denies disabled people the visibility and resources we need to survive.

The proposed revision to disability data collection also poses consequential risks to the government’s ability to support disabled people in preparing for emergencies and responding to the needs of disabled people during emergencies. Accurate data on the number of people with disabilities is a cornerstone for local and national emergency planning. This data informs evacuation strategies and shelter accessibility, helping inform equitable resource allocation to meet the needs of all community members during crises. An undercount of the number of people with disabilities can lead to insufficient planning, allocation of resources, and life-threatening situations during emergencies, disasters, public health emergencies, and other crises. The failure to accurately capture the number of people with disabilities in community planning can result in ineffective and non-inclusive emergency response strategies, ultimately putting lives at risk. Without an accurate count of the number of disabled people in our nation, we cannot rectify the disability discrimination that is still pervasive throughout our society, and specifically throughout emergency management.

We emphasize the importance of consulting Disability Community leaders before implementing such a crucial change. Including diverse perspectives from people with disabilities, researchers, and disability-led organizations in the decision-making process will ensure a more accurate and comprehensive understanding of the diverse experiences and needs of the Disability Community. A key principle of the disability rights movement is Nothing About Us Without Us. We hope that the Census Bureau adopts this philosophy as it refines methods of collecting accurate data that provide a clear picture of the Disability Community.

While we recognize the need to update and improve the ACS and the PRCS, it is imperative that these changes do not come at the cost of underrepresenting and, thus, further marginalizing the Disability Community. We urge a reconsideration of the proposed methodology in favor of one that fully captures the breadth and diversity of people with disabilities in the United States of America.