Attachment B 2020 thru 2022 Summary of Public Comments.pdf
PDF 105 KB Posted
- Attached to
- UNIFORM CITATION DATA ANALYSIS AND REPORT RFR
- Solicitation number
- BD-26-1044-EPS11-1044O-129244
- Issued by
- Massachusetts
About this file
This document is a summary of public comments received regarding the 2020 through 2022 Uniform Citation Data Analysis Reports conducted by the Massachusetts Office of Governor and Regulatory Affairs (OGR) in response to an RFR soliciting proposals from Massachusetts-based universities, non-profit organizations, and institutions with expertise in analyzing demographic information from motor vehicle stops. The reports analyzed traffic stop data to identify potential racial disparities in law enforcement practices. Public commenters raised extensive concerns about the methodological approach employed across all three years of analysis, including criticisms of the Veil of Darkness methodology, insufficient racial category distinctions, exclusion of verbal warning stops, use of state-level demographic benchmarks rather than local data, and inadequate investigation into root causes of identified disparities. Additional methodological concerns included questions about data completeness, police officer accuracy in recording race and ethnicity, and the exclusion of stops where no citation was issued.
Beyond methodological critiques, public comments addressed the research process itself, requesting greater stakeholder involvement, in-person researcher participation in public hearings rather than video presentations, expanded public engagement opportunities including evening sessions, and release of de-anonymized data to the public. Commenters questioned the independence of the research team, noted that analysis conclusions contradicted both community experiences and findings from comparable studies such as the Vera Institute research on Suffolk County traffic stops, and questioned what consequences, if any, would result for police departments identified with disparate stop outcomes. Additional recommendations included conducting audits of race and ethnicity designations, exploring federal funding sources such as the National Highway Transportation Safety Administration grants, and providing stand-alone reports for individual analysis years.
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2020 Uniform Citation Data Analysis Report Summary of Public Comments Received
Methodological Shortcomings
• Does not recognize historic disparate treatment of people of color.
• Police officer identification of race/ethnicity.
• No verbal warning stops included.
• Veil of Darkness did not address factors such as lighting, weather patterns, licenses/registrations checked, profiling, daylight savings time.
• Veil of Darkness assumption that officers can determine race of drivers during daylight is disputed and use of mobile data terminals undermines officer perception regarding race.
• Other analyses methodologies should have been used.
• Population benchmarking a better approach than VOD.
• Driving population needs to be identified as a starting point for analysis.
• Racial categories of White and Non-White categories are insufficient.
• Driving patterns may differ for racial groups between light and dark.
• Post stop outcomes not accurately summarized.
• Regression formula not included.
• Individual police department analyses should include stopped residents rather than stopped motorists.
• Local demographics should be used instead of state average.
• Causes of disparities should have been investigated.
• Statistical methodology was criticized.
• Cognitive biases in research should be addressed.
Other Comments
• Analysis conclusions differ from study by the Vera Institute on Suffolk County traffic stops.
• Press released did not present finding of racial disparities appropriately; identified "flagged" departments at the end of the release.
• Analysis conclusions are at odds with people of color experiences.
2021 and 2022 Uniform Citation Data Analysis Report Summary of Public Comments Received
Methodological Shortcomings
• Concerns raised about the independence of the research team.
• Limited expert and stakeholder involvement and outreach.
• Concerns about the completeness of the Uniform Citation Report dataset.
• Deviations from best practice in the use of the Veil of Darkness.
• Too much emphasis on the Veil of Darkness over other analyses.
• Omission of several best practice additional tests.
• No racial/ethnic analysis of verbal warnings.
• Aggregating all non-white drivers into a single category may conceal racial profiling of specific groups.
• Did not account for systematic undercounting of Hispanic and Latinx drivers.
• Statistically significant findings were de-emphasized.
• Failed to recognize the history of disparate police treatment of communities of color.
• No stand-alone report for 2021.
• Concerns about police officer recording of race/ethnicity data.
• Need to collect data on all stops, not just stops where a citation is issued.
• Researchers lack familiarity with research on traffic stops.
• No breakout of stops and stop outcomes for residents of each municipality.
• Release de-anonymized dataset to public.
Other Comments
• Federal National Highway Transportation Safety Administration funds are available to support racial profiling studies (only state funds were used).
• What happens to police departments with disparate findings?
• In addition to the daylight public hearings, sessions should be offered in evenings.
• The Public should have opportunities to engage with the researchers in public hearings.
• Use of video recordings for the researcher’s presentation in public hearings was not sufficient, researchers should present in person.
• Will there be an audit of a subsample of race/ethnicity designations as recommended by the researchers?
| 2020 Analysis Comments Received |
| 2021 and 2022 Analysis Summary of Comments Received |
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