November 6, 2010
To: Vincent Osier,
Chief, Geographic Standards and Criteria Branch
Bureau of the Census
From: Wendell Cox
Dear Mr. Osier:
Demographia is pleased to offer comments on the Proposed Urban Area Criteria for the 2010 Census. Demographia is an international consultancy, which reports demographic information and compiles the only known estimates of population, land area and population density for all identified urban areas (nearly 800) in the world with 500,000 or greater population (Demographia World Urban Areas). Our comments are as follows:
(1) Eliminate the urbanized area and urban cluster terms and replace them with "urban areas:" There seems to be no reason to continue the separate "urbanized area"/"urban cluster" terminology. Under the proposed criteria, urban areas with 50,000 or more population would continue to be called urbanized areas, while smaller urban areas would be called urban clusters. The 50,000 dividing line is artificial. Both urbanized areas and urban clusters are now designated urban areas by the Bureau of the Census and there seems no good reason to keep the urbanized area and urban cluster terminology. Both should simply be called urban areas.
(2) Error in notice on San Diego-Mission Viejo agglomeration: We notice that the list of agglomerations includes San Diego-Mission Viejo and that the Proposed Urban Area Criteria states (page 52180) that these two urban areas are within the same metropolitan statistical area (MSA). This is incorrect. The Mission Viejo urban area is in the Los Angeles MSA and the San Diego urban area is in the San Diego MSA. We further wonder whether this agglomeration might have been created by some application of the National Land Cover Database, that might have considered Camp Pendleton to have been urban (which would have created the required continuous urbanization between San Diego and Mission Viejo). It seems likely based upon examination of late satellite photography, that Mission Viejo will be included in the Los Angeles urban area through the automated Bureau of the Census delineation process.
(3) Redefine urban areas following final delineation of metropolitan areas based upon the 2010 Census: It appears that urban areas will be defined (and split within agglomerations) based upon the MSA boundaries as defined after the 2000 census. This is understandable for the period that precedes final delineation of MSAs based upon 2010 census results. However, urban areas should be redefined as quickly as possible using 2010 MSAs as defined based upon the 2010 census. Given the automated nature of urban area delineation, such a redefinition should not be cumbersome and would result in a more accurate portrayal of urban areas.
(4) Establish combined urban areas corresponding with combined statistical areas where the continuous urbanization extends beyond the metropolitan statistical area: The Bureau of the Census designates combined statistical areas (CSAs), which are, in effect (and were formerly called), consolidated metropolitan areas. There should be a parallel urban area designation, perhaps called a combined urban area, based upon combined statistical areas (where the principal urban area extends beyond the principal MSA into other MSAs within the CSA). Such a designation would recognize the strong economic and other connections within CSAs, particularly in CSAs such as New York-Newark-Bridgeport, Los Angeles-Riverside and San Francisco-San Jose. In each of these cases, the urbanization may be considered not only continuous but lacking of any material geographical narrowing (at least in 2010, based upon examination of satellite photography).
St. Louis urban area, MO-IL