Response Letter Regarding Federal Register Notice Vol. 82 No. 39

Identifier

ar_011

Title

Response Letter Regarding Federal Register Notice Vol. 82 No. 39

Description

Letter to U.S. Chief Statistician proposing ME/NA be regarded as an ethnicity in federal documents

Creator

Islamophobia Working Group (University of Michigan)

Subject

Arab Americans -- Michigan -- Ann Arbor

Middle Eastern students -- Michigan -- Ann Arbor

Student organizations -- Michigan -- Ann Arbor

University of Michigan -- Students

Source

https://hdl.handle.net/2027.42/149171

Publisher

Islamophobia Working Group (University of Michigan)

Spatial Coverage

University of Michigan -- Ann Arbor

Washington D.C.

Date

2017

Type

Text

Format

text/PDF 86 kB

Rights

This content may be under copyright. Researchers are responsible for determining the appropriate use or reuse of materials.

Rights Holder

Copyright is held by the Regents of the University of Michigan but the collection may contain third-party materials for which copyright is not held. Patrons are responsible for determining the appropriate use or reuse of materials.

Language

Eng

Provenance

Letter originally written (2017) and saved (without alteration) by the Islamophobia Working Group (University of Michigan) on 2019-01-28 to be compiled with a larger collection about MENA students and activism.

Bibliographic Citation

[item], https://deepblue.lib.umich.edu/handle/2027.42/149169, Islamophobia Working Group (University of Michigan) records, Bentley Historical Library,
University of Michigan

extracted text

The Office of the U.S. Chief Statistician
Office of Information and Regulatory Affairs
Office of Management and Budget
9th Floor, 1800 G Street, N.W.
Washington, D.C. 20503
Race-Ethnicity@omb.eop.gov
Dear Dr. Nancy Potok:
I am writing in response to the Federal Register notice Vol. 82, No. 39 published on Wednesday
March 1, 2017 regarding the “Proposals from the Federal Interagency Working Group for
Revision of the Standards for Maintaining, Collecting and Presenting Federal Data on Race and
Ethnicity.”
I.

Classification of Middle Eastern or North African Category
a. MENA is an Ethnicity: If MENA is collected as a separate reporting category,
MENA must be considered an ethnicity. We maintain that persons with origins in
the MENA region (much like those of Hispanic origin) identify with many racial
backgrounds and that ethnicity is the appropriate approach to this new category.
b. Conditional Minimum Reporting Category: As an ethnic classification, the MENA
category must be treated equally and not be subsumed under any other major OMB
tabulation category. The MENA ethnicity category must become a required minimum
reporting category if the sample size is sufficient to meet the threshold
requirement for no disclosure risk and reporting given that guidance is provided
to all collection agencies.
c. Special Groups: All groups with origins from the Middle East and North Africa who
self-identify with this region (such as Assyrian/Chaldean, Coptic, or Druze) must
be included in the MENA ethnic category. The Census Bureau already collects and
reports information on the largest group Assyrian/Chaldean while others (e.g. Coptic
and Druze) have been invisible within the MENA population.
d. MENA Definition: (a) Like any other major OMB tabulation category, the MENA
ethnic category must represent persons with origins in the Middle East and North
African regardless of their nativity status or parental place of birth; and (b) We
request that the IWG and OMB adopt a comprehensive geographic definition of the
MENA category that includes the population with origins in the League of Arab
States (Algeria, Bahrain, Comoros, Djibouti, Egypt, Iraq, Jordan, Kuwait, Lebanon,
Libya, Mauritania, Morocco, Oman, Palestine, Qatar, Saudi Arabia, Somalia, Sudan,
Syria, Tunisia, United Arab Emirates, and Yemen); Non-Arab MENA States
(Turkey, Iran and Israel) and Trans-national communities (Assyrians/Chaldeans,
Kurds, Berber, etc.).

II.

Cost, Burden and Security: (a) Requiring an additional reporting category for MENA across
federal information collections recognizes this growing American ethnic population that has
been mostly invisible in federal statistics and reports, and yet remains hyper-visible in our
country’s political, policy, law enforcement and security arenas. We believe accurate and
inclusive data collection on the MENA population will inform policymakers, federal and

local officials, service organizations, and the public on the status of these communities, their
needs, and the assets they bring to local, national and international issues. (b) Given the
estimated size of the MENA group, a separate reporting category should be required when
reporting allows for statistically reliable estimates because collecting data with a high margin
of error is useless; (c) A separate reporting category should be required when reporting meets
the requirement for no disclosure risk and does not risk the confidentiality or privacy of
the MENA population; (d) We request assurances that all laws protecting confidentiality be
strictly enforced with significant penalties on breaching confidentiality. Furthermore, when
special tabulations are requested beyond what is publically available, mechanisms that ensure
transparency must be maintained.
III.

Additional Minimum Reporting Categories: In addition to the groups listed in the FRN, we
recommend that OMB issues specific guidelines for the collection of detailed ethnicity data
for MENA as follows:
a. If issuing specific guidelines for the collection of detailed MENA ethnicity data,
OMB should NOT adopt the NCT format, which treats the Middle East and North
Africa as two separate regions, and further divides the Middle East into Arab and
Non-Arab. Instead, we recommend that the OMB treat the region as one geography
that is very complex and diverse, and that the sub-boxes be assigned to the largest
groups by population in the U.S. (Lebanese, Iranian, Egyptian, Syrian, Iraqi and
Israeli) while using the examples to include an trans-national group (e.g.
Assyrian/Chaldean), a Gulf population (Yemeni) and an Arabic-speaking country in
sub Saharan Africa (Sudan).

III.

Questionnaire Format and Information Quality: (a) We strongly support a combined question
format which treats the MENA ethnicity as equal to all OMB categories; (b) when evaluating
anticipated information quality, additional testing should be considered on the MENA ethnic
category to achieve the following: i) should the separate questions format be adopted, the
MENA category must be tested in the ethnic origin question (which was not achieved in the
NCT); ii) the MENA question should be tested along with removing the Somali example
from the Black/African American question in all formats; iii) the MENA question should be
tested with examples that include Sudanese, Somali and Nubian as well as
Assyrian/Chaldean.
Thank you for your attention to this important matter.
YOUR SIGNATURE AND AFFILIATION (if applicable).