Protect Federal EEO Workforce Reporting - RIN 3046-AB37

I respectfully ask Congress to intervene through oversight and formal comment regarding the Equal Employment Opportunity Commission’s proposed rule, “Removal of Reporting Requirements,” RIN 3046-AB37, which would eliminate the active EEO-1, EEO-3, EEO-4, and EEO-5 workforce reporting systems. Comments are due August 24, 2026. This proposal does not repeal Title VII, but it would remove much of the standardized demographic information that has allowed the EEOC and state and local enforcement partners to examine workforce patterns over time. As an art teacher in New Bedford Public Schools, I am particularly concerned about EEO-5. Massachusetts reports more than 1,000 teacher FTEs in New Bedford alone. An individual teacher cannot independently reconstruct district-wide historical patterns in hiring, occupational assignment, or advancement. If standardized reporting stops, missing years cannot simply be recreated later. Congress should scrutinize the abrupt factual reversal underlying this proposal. In April 2025, EEOC formally certified to OIRA that EEO-1 was necessary for the proper performance of agency functions and that resources had been allocated for efficient use of the information; OIRA approved the collection without change in May 2025. EEOC’s 2023 materials described the data as useful for prioritizing and focusing investigations, identifying possible systemic issues, employer self-assessment, and state and local enforcement. Recent EEOC materials similarly documented investigative uses for EEO-3, EEO-4, and EEO-5 and an agency data infrastructure built around these collections. Yet the July 2026 NPRM now describes these collections as having limited practical utility and asserts that charge-specific information is more reliable and cost-effective. Congress should require the Commission to identify the evidence supporting that reversal. I ask Congress to submit comments opposing abolition of the active reports on the present record; request the underlying evidence and comparative cost analysis; examine consequences for state and local civil-rights agencies under Title VII § 709(d); require consideration of less burdensome alternatives such as reduced frequency, higher thresholds, sampling, and modernized categories; and, if necessary, use legislation and appropriations oversight to preserve a reliable federal employment-data infrastructure. Civil-rights law is difficult to enforce when evidence capable of revealing patterns is allowed to disappear. Congress should insist upon a complete factual record before this infrastructure is dismantled.