First, two clauses of the proposed regulation may be contradictory.  Specifically, under the laws of some states, an ID that is not valid no longer has "legal effect, legally or officially acceptable or of binding force," or may not be for the period of time provided in the proposed regulation.  Is there any consideration given to whether the issuing authority considers the ID valid within 30 days after expiration?

Second, the proposed regulation makes no mention of what is an acceptable "issuing entity."  Federal and state government IDs?  City IDs?  Work IDs?  Postal IDs?  Foreign government IDs?

Third, what standard of evidence is meant by "reasonably appears?"  The preponderance of the evidence?  Clear and convincing?  "Reasonable" is usually reserved for criminal matters, which must be established beyond a reasonable doubt.

Fourth, I am opposed to removing the language regarding a photograph.  Not all valid IDs issued by all entities have an identifiable photograph.  By removing the word "photograph" from the definition of valid, you are opening it up to accepting non-photo ID.