Make your own free website on

March 13, 2002




Madeleine Clayton

Departmental Paperwork Clearance Officer

Department of Commerce

Room 6086

14th and Constitution Avenue, NW

Washington, D.C. 20230


Dear Ms. Clayton:


This letter responds to the January 16, 2002, Federal Register Notice that requested comments on the American Community Survey.  The Data Task Force of the Standing Committee on Planning (SCOP) of the American Association of State Highway and Transportation Officials (AASHTO) submits for your consideration the following concerns.


The implementation of the American Community Survey, as a replacement for the Census Bureau long form, is of extremely critical interest to AASHTO SCOP member states.  For over three decades, Census Bureau long form data on journey to work characteristics have provided information essential to transportation planning and the analysis of transportation investment alternatives.  In recent years, both the Executive Branch and Congress have broadened the analysis responsibilities of state departments of transportation, increasing the demand for and importance of Census long form data.  Because of the significant value derived from these data, there are several factors that we believe warrant consideration as you move forward with implementation of the American Community Survey.  These factors include:


1.      The need for timely, comparable, and representative data.  Quality data are needed that permit analysis of population changes, journey to work flows, and mode use in both larger and smaller communities and at larger county and smaller census track and transportation analysis zone (TAZ) levels.



Larger areas with populations over 65,000 will be provided with data every year beginning in 2004.  Smaller areas, even those undergoing rapid change, will have to wait longer for data, with results averaged over 2, 3, 4 and 5-year time periods depending on population size.  This means that areas with populations of less than 20,000 people will wait until 2008 for data that has been averaged over a five-year period.

2.      Sample sizes, scheduling and frequency of sampling periods and data averaging methods will have ultimate effects on data comparability and data quality, particularly at census track and TAZ levels.  Decisions affecting these factors must be sensitive to methodological concerns as well as the transportation planning needs of both larger and smaller communities.


3.      The need for full testing and analysis of data products.  Full testing and analysis are needed to provide greater insights into the comparability and constraints associated with American Community Survey results.  Decisions to discontinue the Census long form should only be made when sufficient testing and analysis demonstrate to users that the American Community Survey can serve as a good replacement.


4.      The need for on-going collaboration, communication and cooperation with the transportation community. The American Community Survey has great potential for increasing the quality of demographic data.  It is also important to ensure adequate transportation related information is collected.  For this reason, it is essential that Census Bureau, and other federal agencies involved in the collection of American Community Survey data, work closely with data users from the transportation community. We stand ready to assist in this effort.


We appreciate the opportunity to comment on this important matter and look forward to working with the Census Bureau on the implementation of the American Community Survey.  




Jonette Kreideweis


Data Task Force of the AASHTO

Standing Committee on Planning