Text of LEOSA when it was HR 218...
‘‘(d) The identification required by this subsection is the photo-
graphic identification issued by the governmental agency for which
the individual is employed as a law enforcement officer."
The grey area comes in the definition of the word "employed." How grey? Charcoal. If you catch a case while trying to use your fantasy LEO credentials to justify LEOSA for yourself, then the case will come down to the judge/jury having to decide whether you are actually "employed" as a LEO. You may conjure up a scenario in which you may consider yourself employed when you do not do something as your main source of income, and you do not do it for, say, at least 30 hrs/week, but will the judge/jury actually buy this alternative definition of "employed"? Hey, take your chances.
That being said...
CA AG says that LEOSA applies to active, sworn reserve officers... http://caag.state.ca.us/firearms/forms/pdf/leosiss.pdf
. Many departments specifically prohibit reservists from being being paid (+ no benefits, + no POA, + no retirement)... which would reasonably make them non-employees of the dept. and, following a strict reading of LEOSA, not grant CCW. So, a bit of a contradiction there. Then again, the AG doesn't make the law... this is just his interpretation of it.
So, there you go.