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On April 30, 2010, the U.S. Department of Education launched its Promise Neighborhoods program and described it as “the first federal initiative to put education at the center of comprehensive efforts to fight poverty in urban and rural areas” (U.S. Department of Education, 2011). Unlike its signature Race to the Top program, which has awarded more than $4.35 billion to states and districts to encourage competition over collaboration, standardization over supports, and privatization over leveraged and sustained investments in public schools; Promise Neighborhoods is committed to combating poverty and improving schools through its focus on out-of-school factors and their relationship to student learning and achievement. This paper examines the Department’s Promise Neighborhoods program as a community-based approach to improving schools in poor and distressed urban neighborhoods. It begins with an overview of the federal grant program and brief profile of the urban communities awarded planning and implementation grants since the program’s launch in 2010. Using critical policy analysis methods, we consider the aims of the policy according to its own policy goals, which focus on building community capacity and leveraging community assets as an approach to improving student achievement outcomes in persistently low-achieving schools. More specifically, we present data from the Las Vegas Promise Neighborhood Initiative to illustrate the ways in which a low-capacity, high-transient community in the American West - with little to no history of grass roots organizing and activism - faces particularly unique challenges in building the coalitions and capacity needed to transform struggling schools. The paper concludes with research and policy recommendations geared specifically toward low-capacity communities in their ability to initiate and sustain meaningful and measurable community-based school reform.