Population Association of America (PAA), the PAA Committee on Population Statistics (COPS), and Association of Population Centers (APC), response to the notice in the 27 January 2023 Federal Register requesting comments on initial proposals for updating the Office of Management and Budget (OMB) statistical standards on race and ethnicity. These new standards would replace the current standards, in effect since 1997, that are described in the Statistical Policy Directive No. 15L Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (SPD 15).