CPG 1-15, as reissued March 18, 1991, is on the FEMA Web page.
It reads as follows:
General Information, 1.5
b. RACES is a special part of the amateur operation sponsored by the Federal Emergency Management Agency (FEMA).
There was, unfortunately, a misunderstanding on the part of the author of that publication. The correct statement as to who "sponsors RACES" is that it is the agency that authorizes and uses the unit. If you have a unit in your parish, county, or city, then that is the SPONSOR of that RACES unit, and it needs NO FCC or FEMA approval. If FEMA disappeared entirely every RACES unit would still exist.
It hasn't helped that certain publications printed and reprinted the same misconception, some of which are still in print. Some even seem to interpret the wording of CPG 1-15 to mean that FEMA "controls or manages" the RACES. That is not factual either.
The role of FEMA is, and was, to provide guidance, not direction and control. Today the RACES guidance FEMA offers through 1991 CPG 1-15 is incorrect and contains details not required (neither FCC nor FEMA sign a RACES Plan), and overlooks various aspects of RACES.
We have drawn over 50 RACES Plans for local governments using our model RACES plan (for ease of use and in aid of cooperative mutual aid). Each LOCAL GOVERNMENT is the sponsor of their unit. We did NOT submit any of those plans to the FCC or FEMA for approval. (We do send a copy of the signed plan to the FEMA Regional Office so that IF funds ever become available from FEMA, then the local jurisdiction can apply, but for no other purpose.)
Even the background statement on RACES (in CPG 1-15 1.5.a) missed the mark when it said "RACES is an organization of amateur radio operators who volunteer...." While that is seemingly a generic overview it has been interpreted to mean that ONLY Amateur licensees can belong to RACES, which is not the case. The correct statement would be, "RACES is a Service authorized by the FCC, which, when operating on the Amateur Radio Service frequencies, requires that the operator be FCC licensed, and one who must belong to a RACES unit of a State or Local government." Those in a RACES unit not licensed obviously cannot operate the radio but can provide other needed services, and do so in many RACES units.
The FCC regulations are empowering; that is, they AUTHORIZE A SERVICE in accord with specific regulations for that service. Several misconceptions come from not realizing that basic premise.
The next bulletins cover successful and unsuccessful units, and some reasons why.