That's right, not company-specific, not plant-specific, that CEPA depend wholeheartedly on voluntary approaches to pollution prevention.
What individual industry representatives might tell you over lunch at those meetings, however, is that regulation would have been a lot easier, that it would have saved the department a tremendous amount of resources and they would have known what they were dealing with. Constantly coming back and trying these new voluntary approaches that didn't work was frustrating to them as well as to environmental advocates, who of course wanted to see progress.
You won't get a trade association to say that, because you're quite right: it's the highest common denominator, not the lowest. So that's a reality for you, and there's really not much I can do to help you wade through that. It's just the reality of the situation.