All that says is the relief requestor doesn't have to necessarily follow the standard procedure (which is forms, letters, copies to certain agencies, and so on and so forth as the bureacracy goes) for making the request. E.g., a phone call might be enough in certain circumstances.
Waiving the assistance requestor's duty to follow standard procedure does not suppoert the assertion "that DHS had the authority to roll FEMA into this on its own accord."
Bubba says people were killed in a NOLA flood during his first term. Near the end of his 2nd term, he said a study was completed analyzing the levee system. Says he doesn't know what happened to the study.
I have no desire to sit here and argue esoterica regarding the language of either the NRP or the Stafford Act. The NRP flat out says that issues of allocation of authority should not delay the response. So it makes no sense to argue that a delayed response was caused by issues of allocation of authority.