FYI-Official Business

Below are the abbreviated comments from Project RACE in response to the current Federal Register notice regarding the 2020 Census. The comments were submitted on January 14, 21015. We are awaiting confirmation notification. Staying current with the planning for the 2020 Census and drafting responses to official notices is just one of the things Project RACE does for the multiracial community.


January 14, 2015

Re: Comments on 2015 National Content Test

Project RACE (Reclassify All Children Equally) respectfully submits the comments below regarding the 2015 Optimizing Self-Response and Census Tests. We are the national advocates for multiracial children and their families. We are often rendered invisible by federal agencies in the discussions and planning for racial and ethnic classifications. We are concerned with ways to enhance the quality, utility, and clarity of the information to be collected in the 2020 Census regarding race and ethnicity.

As you know, the 2000 Census partially accommodated multiracial respondents by allowing us to check more than one racial box. The request by the multiracial community to use the preferred term “multiracial” was denied then and for the 2010 Census. As a result, multiracial respondents who checked more than one race are called “MOOMs” (Check One Or More), “Two or More Race People,” or “In Combination” respondents for purposes of tabulation. Tabulation wording does influence common usage because it is a descriptor of the total numbers.

OMB advised federal agencies to utilize “in combination” in its guidance for federal data on race and ethnicity in December, 2000. However, there has been much confusion about the nomenclature since 1997 when OMB specified, “When the primary focus of a report is on two or more specific identifiable groups in the population, one or more of which is racial or ethnic, it is acceptable to display data for each of the particular groups separately and to describe data relating to the remainder of the population by an appropriate collective description.”

Our requests for utilizing the word “multiracial” on the federal forms has been denied, even though it is important for multiracial children to see a descriptive word for themselves that is correct, respectful, and accurate. We work with many schools, medical facilities, clinical trials, etc. that do use the term “multiracial” on the forms with these directions: If you are multiracial, you may select two or more races. We would like to see testing of this wording on the instructions for the 2020 Census. Census Bureau personnel have indicated that will not happen. We have not been given any reason and our suggestion was not tested.

The instructions for indicating a person’s races are critical to the clarity of the category, which can affect the total numbers of people across all racial classifications. The multiracial population needs assurance that we will not lose numbers based on how the question is asked. “Mark X one or more boxes” proved to be confusing. Our hope is that the testing of “Mark all boxes that apply…note, you may report more than one group” will prove more effective for the multiracial population.

It would be very meaningful to the multiracial population if the appropriate term is at the very least used for tabulation, replacing “in combination.” Ironically, the Census Bureau often uses the term “multiracial” when discussing this population and in presentations, but not in its “official” data collection. If you seek clarity, the term “alone” should be dropped or changed to “racial,” and the term “in combination,” should be changed to “multiracial.” To give an example, consider that the decisions of the OMB and Census Bureau are often reflected by the media. When we see a racial and ethnic pie chart in a newspaper or Internet story, we want to see the multiracial community represented as “multiracial,” not “combination people” or “other.” Both OMB and Census personnel know perfectly well that proper nomenclature is extremely important when used to describe race and ethnicity, yet it is completely disregarded when it comes to only one population group—multiracial.

Additionally, it is reprehensible that OMB Bulletin No 00-02, Guidance on Aggregation and Allocation of Data on Race for Use in Civil Rights Monitoring and Enforcement (March 9, 2000) sets forth racially insensitive instructions in its EEO Enforcement instructions, whereby a person who checks more than one race is assigned to one of their minority races. Discrimination is often the result of a person designating more than one race, and to be reassigned to one race only defeats the purpose of enforcement of Title VI of the Civil Rights Act of 1964. Unfortunately, we see cases where multiracial children are bullied because they are multiracial, and they have no protection in that eventuality under the OMB guidelines.

We ask that these issues be revisited in testing for the 2020 Census. Changing “in combination” to “multiracial” would mean government acceptance of a word that is very widely used by non-governmental entities. It would also indicate sensitivity for proper nomenclature that is given to other racial groups, which we have been asking for since 1990. Any consideration that can be given to this demographic group that is rapidly and substantially increasing would be appreciated by the multiracial community.



Susan Graham

Executive Director

Project RACE




















Government Deals

Dealing with the Federal Government

Have you ever tried to deal with the federal government? There are no good ways for us (the public) to have input into whatever it is that they (the federal government) wants to do. They think the way for us to speak our minds is through something you’ve probably have never heard of called the “Federal Register.”

The Federal Register is a publication put out by OUR government to elicit input from the public. It is not easily found, nor is it easily decipherable. It’s a feel good mechanism for federal agencies. They do offer a 109 page booklet called “Federal Register Document Drafting Handbook.” They also offer a very long tutorial. I could not find the answers to any questions I had in their booklet, in the tutorial, or on their website.

Make no mistake; the Federal Register exists only to allow the federal agencies to feel that they gave the public a chance to reply. They don’t really want or need our input.

I read the Federal Register every day. It’s boring and complex. I read it because occasionally a notice appears that may have implications for the multiracial community. The government knows we are here and watching, yet they do not notify us when something is going on that may affect us. I bet I’m the only person in the multiracial community who reads it every day and answers when it matters.

There is no real accountability in the federal government. The notices are packed with government jargon and intentionally make it difficult to get to the real issues. I came across a Federal Register notice several weeks ago that could have implications for Census Bureau testing, which does involve us. I had a question about it and emailed the person specifically designated in the notice “for further information.” The email came back to me as “undeliverable.” I called her. I have yet to receive a return call. Welcome to the public trying to deal with the federal government through their Federal Register.

I’ve spent several days trying to get more information so that I could make a public comment on behalf of the multiracial community. I have made no progress. I did email the Fed Reg (they like to be called that) people and I think their convoluted answer said they had no answers. They did add, “Our goal is to make it easy for you to communicate with the government.”

So the Fed Reg people sit on their well-paid duffs and say they are soliciting comments from the public. When you figure out how to do that, let me know.


Susan Graham



The Census Bureau Club

The Census Bureau Club: How they choose committee members

We frequently receive questions about why Project RACE does not have a representative on the Census Bureau National Advisory Committee on Race and Ethnicity (NAC). I will explain how it works and why it’s a bogus committee in the first place.

The Census Bureau chooses who will be on the NAC. They vet all of the recommendations and carefully choose the “yes people.” They advise the public of the call for nominations using the Federal Register. One time only. If you happen to miss the standard notification that day, you will miss the entire opportunity to have input on the next (2020) U.S. Census. However, if the Census Bureau personnel like you (meaning you are a total doormat who will do what they want, what they say, and when), they will probably contact you or make sure you are placed on the committee. I expect we will see some familiar names in the current next go-round.

Project RACE’s desired Census 2020 configurations for race and ethnicity are hardly what the bureau wants. Census Bureau Director John. H. Thompson has made it very clear that it would be uncomfortable for them to have our input. We are not “yes men or women” and that just confounds them. They choose the people they can mold, not the people who might cause them to think about what is really fair and just for the multiracial community.

In some ways, they are right: Census and Project RACE are not a good fit. But what happened to free speech and democracy? We have inquired and been told that we are entitled to the transcripts from the NAC meetings. Transcripts take about four weeks to receive after the meeting. We have requested the transcripts from the March meeting four times now, and have yet to receive them.

Multiracial people will remain invisible at the Census Bureau, and that’s just how they roll.

Susan Graham

Federal Response

Below is a letter sent in response to a Federal Register entry. Your advocates at Project RACE read the Federal Register daily and respond when necessary for the multiracial community. 


December 20, 2013


Stephanie Valentine

Acting Director

Privacy and Information Collection Clearance Division

Privacy, Information and Records Management Services

Office of Management

United States Department of Education

400 Maryland Avenue, SW, LGJ Room 2E105

Washington, DC 20202-4573


Submitted through the Federal eRulemaking Portal


Re: Comments on Mandatory Civil Rights Data Collection

Docket ID Number ED-2013-ICCD-0079

Proposed 20113-14 Civil Rights Data Collection



Dear Acting Director Valentine:

Project RACE (Reclassify All Children Equally) respectfully submits the comments below regarding Civil Rights Data Collection. We are the national advocates for multiracial children, teens, adults, and our families. We were founded in 1990 to represent those of us who are affected by Washington, but are not a large lobbying entity. As a result, we are often rendered invisible in the discussions and planning for racial and ethnic classifications. Our national members and supporters are therefore concerned with the Mandatory Civil Rights Data Collection.

Our recommendation is very simple. The Office of Civil Rights (OCR) includes a classification of “Multicultural or Multiethnic or Multiracial” under “the major racial and ethnic groups states use for accountability and assessment data.” Yet the Department of Education (DOE) does not list “Multicultural or Multiethnic or Multiracial” in its racial and ethnic choices stated under “The general racial ethnic categories that most clearly reflect individuals’ recognition of their community or with which the individuals most identify.” Their list includes “Two or more races.”

First, there should be consistency between agencies. Second, the preferred terminology used most by the multiracial community is “multiracial.” We would alternatively be inclined to accept some form of the OCR’s “Multicultural, Multiethnic, or Multiracial.”

Many school districts have also adopted the following wording on their forms: “If your child is multiracial, you may select two or more races,” followed by the specific racial and ethnic list of categories in compliance with their state departments of education. This is the suggested wording provided by the multiracial community.

It is vitally important for students to be able to be included in civil rights categories and be equally protected under civil rights protections. It is time to recognize our multiracial students in our schools and give them the dignity of proper terminology as an important   part of their civil rights protection.



Susan Graham

Executive Director

Project RACE, Inc.