Seems there should be a requirement to give back the old license, like with a driver's license, so that if it's revoked you don't have another "backup."
I don't see any reason they should do more than a cursory check to at least make sure you somewhat resemble the person on the license. After all, if you get into a situation where an LEO needs to see your CHL, you better match anyway.
I don't see why there should have been a replacement fee. Sounds like there wasn't much effort involved - probably just popping a blank card into a machine once she had your file.
Then again, I was talking to my aunt the other day about concealed carry, because I know that she did (or used to) she told me she didn't renew last time because they started charging. I looked at her like "You serious? They didn't used to charge for them?" Would that I were older (not really, but a free CCW would be nice.
Those are just my opinions, I'm sure someone more knowledgable than I will come along and give you their two cents. Me, I'm still waiting for the beaurecracy to learn to count to 30 (Maine=shall issue within 30 days)