Response. No. Neither state or federal officials request the FCC to authorize the use of the RACES; and the operation is not so limited as implied.
RACES operation is authorized any time activation is requested by the local or state official with that authority as specified in the jurisdiction's RACES plan.
As to being "limited to official civil preparedness activity....", such statements seem to echo words in Part 97.407(e) and do convey the idea that RACES activities are much more limited that some other service supposedly without limitation. However, in the real world, a government emergency communications unit can do most activities any other unit can do if (repeat IF) so authorized and properly handled, by its sponsoring government civil defense agency for training and familiarization purposes in preparation for emergency communications. The key is how the situation is handled and structured. For more information on how RACES units do utilize the broad flexibility they possess it is suggested that you review the bulletins issued over the past year or so.
Remember, however, that the RACES prime mission is emergency Public Safety Communications support for and on behalf of the local or state government civil defense program. In today's world that includes many activities that do not involve operation on Amateur Radio frequencies.
Cary Mangum, W6WWW, LL.B., JD.,