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The rule's preamble notes that "a program participant's strategies and actions may include strategically enhancing neighborhood assets,- 78 Fed. Reg. 43716, but this strategy should not be implemented in a manner that perpetuates segregation. §5.152. Recognizing that "[s]egregation carries a heavy social cost," 78 Fed. Reg. 43714, the Proposed Rule replaces the Analysis of Impediments (Al) with a new framework—the Assessment of Fair Housing, or AFH—through which program participants must identify, analyze and mitigate barriers to fair housing choice, and ties it to other planning processes through which federal, state and local resources are allocated. In other words, it creates a fair housing lens for all of a participant's decisions about housing and community development needs. Participants must submit AFIls to HUD, which can reject noncompliant AFIls, and impose a range of sanctions for noncompliance, up to and including \vithholding federal funds. The new framework requires greater reliance un data (which will be supplied by HUD), greater transparency and public participation in the development of the AFH, and greater accountability with respect to expanding housing choice. Most importantly, it will require program participants to initiate and follow through on jurisdiction -specific community con \ ersations about race, segregation and access to opportunity areas. Finally, the Proposed Rule emphasises that a participant's AFFH obligation is not bounded by what it can do with the HUD funds it has received. The strategies and actions "will be accomplished primarily by making. investments with federal and other resources...." §5.152; 78 Fed. Reg. 43716. This regulatory language reinforces a provision that has been in HUD's Fair Housing Planning Guide, at p. 1-3, since 1996: Applicability: Although the grantee's AFFH obligation arises in connection with the receipt of Federal funding, its AFFH obligation is not restricted to the design and operation of HUD -funded programs at the State or local level. The AFFH obligation extends to all housing and housing -related acti \ ities in the grantee's jurisdictional area whether publicly or pri' atel:\ funded. Procedural Issues in the Proposed Rule • HUD will provide uniform data sets to allow participants to identify fair housing issues. §5.154(c) • Participants are required to develop and submit an initial AFH to HUD 270 days before the start of the block grant or PHA funding cycle. §5.160(a). If the AFH is not submitted by August 16 of the fiscal year for which funds were appropriated, a participant will automatically lose CD130 funds. §5.160(b). Participants w ill be required to submit an AFH every fie years, §5.160(c), or when "a significant material change in circumstances occurs that calls into question the continued validity of the AFH.,.." /r2 -J.6