September 12, 2006

Patrick J. Sherrill
US Department of Education
400 Maryland Avenue, SW
Room 6C103
Washington, DC 20202-0600

and via email: comments@ed.gov

Re: Guidance for Data on Race and Ethnicity

Dear Mr. Sherrill:

Project RACE (Reclassify All Children Equally) and Teen Project RACE wish to thank the US Department of Education for its wisdom in proposing guidelines that include allowing people to check more than one race on forms in our schools. It is further progress to report such data in a separate category and not redistribute them into single boxes.

To continue DOE's foresight into the future population of schools in America, we urge you to collect the data in the category of "multiracial" instead of "two or more races." It is vitally important to multiracial children in this country to have an appropriate, positive and descriptive name for their category; multiracial is that word.

Ten states have already adopted the term "multiracial" on their school forms. We urge the US Department of Education to endorse the term multiracial as well. Proper racial identity is of utmost importance to children, and that includes proper terminology. We get reports almost daily of administrators and teachers in the United States referring to multiracial students as "a two or more race kid," "mixed," "really black," "check-a-lot," "other," and even "mixed up." Forms in this country no longer use terms like "Oriental," and "Colored." Please give the same respect to multiracial children.

Adding the term "multiracial" would not be difficult. When it comes to collecting and reporting data, we recommend the following format as an option to your proposed guidelines:

Choose one:

• Hispanic or Latino
• Not Hispanic or Latino

Choose one. If you consider yourself to be of more than one race, you may choose "Multiracial," and then select two or more:

• American Indian or Alaska Native
• Asian
• Black or African American
• Native Hawaiian or Pacific Islander
• White
• Multiracial:
• American Indian or Alaska Native
• Asian
• Black or African American
• Native Hawaiian or Pacific Islander
• White

This format would allow the capturing of all multiracial data in one category or when it is necessary (for civil rights purposes, for example), this format would also allow the term "multiracial" with the ability to capture the breakdown of multiracial individual data accurately and easily. This format would satisfy most students, teachers, parents, other educational personnel, data experts, and advocates.

Another, less flexible option, but a compromise we could accept at this time, would be these instructions under race: Choose one. If you consider yourself to be multiracial, mark two or more. Again, it is vitally important to have the term "multiracial" on the actual forms and at the very least, in the instructions.

We advocate a Hispanic identifier in all cases, which is best achieved with the two-question format. Dropping multiple options in the combined format, as the proposal states, is very detrimental and can have serious repercussions. How can Hispanic be an ethnicity in the two-question format, but a race in the combined format? One of our members commented, "My father is Hispanic and my mother is Asian, this (combined format) would still be unfair to me. I would have to pick just one and I am both." This proposed terminology: "Hispanics of any race: and, for Non-Hispanics only," is as confusing as the swing between Hispanics being an ethnicity and a race.

Project RACE members are also advocating for self-identification under any and all circumstances. Our experience proves over and over that observers do not know if a person is Hispanic, white, black, etc. with any degree of accuracy. We think it is everyone's right to choose to not identify their race/ethnicity, and every form that asks for race and/or ethnicity should include a "race and/or ethnicity unknown or unreported" category. This also includes postsecondary forms.

Also, we honestly can't tell from the proposed guidelines if multiracial people might be able to indicate civil rights enforcement/discrimination based on a person being "of two or more races." If Civil rights agencies will be able to go back and contact recipients who have checked "two or more races" and get more information, what then? Would they be reallocated into single groups again? Let's say, as an example, that a black student claimed discrimination. Would the civil rights monitors go back to the check two or more races group forms and check to see if they are part black and then use that number as a group baseline number? Would they let people know they are doing this? Or perhaps they would ask multiracial people the discriminatory and absurd question: If you could be only one race, what would it be?

Data bridging is also not clear. How is the proposed method not a totally arbitrary method resulting in perfectly inaccurate data? This is the example given in the proposal: if a State's new data collection results in 200 students falling in the "two or more races" category at the same time that there is a combined drop in the number in the two single race categories of Black and White students, the state can adopt a method to link the 200 students in the "two or more races" category to the previously used Black and White categories. How would they do that? Make all 200 students black? Make all 200 students white? Make 50% black and 50% white? Or, would they use the antiquated method that gives an arbitrary hierarchy of races and a way to reallocate numbers. Is there no federal guidance on this?

While states will continue to have the right to determine which racial and ethnic groups they want to put on their forms for any and all educational institutions, they will look to the US Department of Education for guidance. It is essential that the US Department of Education sets a standard of acceptance of the appropriate terminology for multiracial students. You can help by being progressive leaders and adopting "multiracial" on forms so that children and parents can actually see the term. We believe that the US Department of Education not only has the obligation to see that our children all receive the best education they can, but that the department can be educators on this issue.

My son and I founded Project RACE when he was six-years-old and in kindergarten. He is now 22-years-old and will graduate from a top university this year. He has lived in two states during his schooling that offered him and schoolchildren like him a category of "multiracial" on school forms. On behalf of the national members of Project RACE and Teen Project RACE, we request that the US Department of Education join these progressive states and endorse the term "multiracial."

Sincerely,

Susan Graham
Executive Director
Project RACE, Inc.