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There's a list of accepted types of primary and secondary photo IDs at https://travel.state.gov/content/travel/en/passports/requirements/identification.html. One of the options there, listed under "Primary Photo IDs", is an "In-state, fully valid non-driver ID with photo".

But, when I tried to apply for a passport using my in-state, fully valid non-driver ID with photo as my "Primary Photo ID", the acceptance agent told me that a non-driver ID wasn't acceptable by itself; she claimed it would only count as a "Secondary Photo ID", and that I'd need to bring in e.g. a driver's license if I want to avoid using "Secondary Photo IDs" (which also requires that I have an "Identifying Witness" present with me, who has their own valid "Primary Photo ID", and I'm not sure that I know anyone who has a driver's license (NYC) that I can also convince to burn several hours at the post office.)

I tried asking the support email, NPIC@state.gov, about this; they replied with a list of primary photo IDs that contradicts what's shown on the travel.state.gov site and does not include "in-state, fully valid non-driver ID with photo". When I pointed out the contradiction, the support agent avoided my question about whether the Department of State website has incorrect information.

So, either the travel.state.gov website is wrong (!!!), and I need to get a driver's license in addition to my non-driver ID for the sole purpose of applying for a passport, or the two workers I've spoken with so far are wrong, and I need to figure out how to find an acceptance agent who understands the requirements correctly. How can I get an authoritative answer on this?

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    I've found references to a document called "Passport Agent's Reference Guide" which appears to be the manual given to acceptance agents by the State Department. It would probably describe the exact rules that agents are supposed to follow. But I haven't been able to locate a copy of the Guide itself. – Nate Eldredge Nov 27 '18 at 1:27
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    Probably if you try a different post office they'll have their own set of rules in questionable grammar typed in all capital letters, but theirs will be different so you might have better luck. – ajd Nov 27 '18 at 4:54
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    @James another thing to try: call the office of your congressional representative and/or senator. Perhaps they can get the law changed to make it explicit that DMV-issued non-driver IDs are equivalent to driver's licenses. More immediately, they may be able to help with the administrative burden in some way, perhaps by clearing up the misinformation. As to the text on the DS-11, the documents on the secondary list are still "documentary evidence," so the statement about requiring a witness with secondary documents also seems to be a misinterpretation. – phoog Nov 27 '18 at 5:17
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    You might also try non-post-office passport acceptance facilities like county clerks or courthouses, depending on what they have in your area. I've heard that sometimes people who had unusual sets of documents that were wrongly refused acceptance of their passport application by the post office had better luck at their county clerk or courthouse. – user102008 Nov 27 '18 at 6:11
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    I agree. Try another agent at another type of passport acceptance facility. – RoboKaren Nov 27 '18 at 9:59
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I can't imagine what the acceptance agent was thinking, non-driver IDs are good for everything driver's licenses are good for except driving--my wife had no problem getting a passport with it. (Although she did also have to present her naturalization certificate which does have a photo on it--but she needed that to show citizenship, not who she was.)

Over the years I have seen plenty of people who do not realize they are equivalent, though, in one case having to get a bank manager involved because the teller would not accept either my wife's non-driver ID nor her passport and kept demanding a driver's license. (Hint: You can't have both a non-driver's ID and a driver's license!)

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    The ability to hold a non-driver ID and a driver license depends on the state; some allow it, some don't. – Gerard Ashton Nov 27 '18 at 4:25
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    @GerardAshton New York is one of the "don't" states. The application form notes that "Applying for a Non-Driver ID card will cancel any NY State driver license privilege." But the point here is to be able to get a passport without having first to get a driver's license, so it doesn't much matter whether one can have both a non-driver ID and a license at the same time. – phoog Nov 27 '18 at 5:20
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The DS-11 instructions read

Proof of Identity
You may submit items such as the following containing your signature AND a photograph that is a good likeness of you: ….

You must establish your identity to the satisfaction of the acceptance agent and Passport Services. We may ask you to provide additional evidence to establish your identity

Note especially the second paragraph: the acceptance agent decides whether the person submitting the application has adequately identified him- or herself by presenting appropriate identification. The type of identification presented is of secondary importance, with some examples provided as to what might be sufficient, but which on its own is explicitly stated to not necessarily be sufficient.

I would think the state-issued in-state non-driver photo ID should be adequate, as in every state I can think of it is issued by the same authority that issues drivers' licenses, and physically produced in a substantially similar format with the same materials, and so on. But evidently your acceptance agent apparently does not agree, and I don't think arguing with them based on some advice from the Internet as to what should or should not be acceptable will get you very far.

This does not mean you need to go get a driver's license, however, as in lieu of a primary photo ID, you can submit multiple secondary IDs such as work or school IDs, Social Security or other benefits cards, and so on. Or, perhaps, you could try again with a different agent.

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    Yes, the first acceptance agent I spoke with didn't even care what the State Department website says, I doubt any of them would care what travel.stackexchange.com has to say either. I'm operating on the assumption that there are some acceptance agents who follow whatever the "guidelines" are pretty closely, even if the rest have their own arbitrary standards, and trying to figure out what the "guidelines" really are. – James Nov 27 '18 at 2:21

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