Office of Information and Regulatory Affairs
Attn: OMB Desk Officer for the Bureau of Labor Statistics (BLS)
Office of Management and Budget
Room 10235
Washington, DC  20503

Dear OMB Desk Officer:

Data on workforce participation are among the most highly valued by policymakers who monitor economic trends. The BLS Current Employment Statistics (CES) survey, one of the key monthly Principal Federal Economic Indicators (PFEIs) in the BLS-790 Series, offers a distinctive employer's-eye view of who holds what job, by industry. For these reasons the American Association for the Advancement of Science (AAAS) appreciates the opportunity to comment on the BLS proposal to revise the collection (Federal Register, April 18, 2005, Volume 70).

Discontinuing the women worker employment series within CES, as BLS proposes, will rob businesses, non-profits, and governments of a vital indicator: how participation by gender in the labor market relates to income and productivity. It will also preclude comparisons between the larger CES survey of 400,000 employers and the Current Population Survey (CPS), which samples 60,000 households. Such "triangulation" boosts confidence in the interpretation of sensitive trends.

The women's worker payroll data are as valuable to wage-earners and researchers who use the information as they are to policymakers who receive it. At the American Association for the Advancement of Science (AAAS), we have learned that you can't know what you don't count. There is an overriding need, as Dr. Shirley Ann Jackson observed in her 2005 AAAS Presidential Address, "to identify, nurture, mentor, and support the talent which resides in our new majority—'the underrepresented majority' population." Women constitute the largest segment of that population. Monitoring their participation can hardly be considered a "reporting burden." Indeed, it is central to the integrity of the data series and the fairness of actions based upon it.

The American Association for the Advancement of Science urges that BLS maintain data-collection through the CES women's worker employment series and continue to inform the nation—employers and employees alike—with ongoing reports on workforce participation trends by gender.

Founded in 1848, AAAS has as one of its principal goals enhancement of the science and technology workforce and infrastructure. From our Board's policy statement of January 1974 on Equal Opportunity in the Sciences and Engineering, to its December 1994 Statement on Discrimination in the Workplace, to February 2005 Statement on Women in Science and Engineering, AAAS has recognized that gender matters.

Sincerely,

Alan I. Leshner
Chief Executive Officer
Executive Publisher, Science