If that's a valid excuse than the CCPA isn't worth the paper its written on.
The rule of any documentation is that it is out of date as soon as the ink is dry. By the time a regulation is enacted, workarounds/loopholes have already been found (if not intentionally worked into it).
I would argue that the request was invalid in the first place.
If I see a flash on a speed camera operated by a business on behalf of a police department, your argument states I should be able to use CCPA to force the business to delete my picture and the record of me speeding If I can get the request to them before the police can file with the court and request that data as evidence.
The data belongs to the government, and you can't get around that right by going to business that holds the data and asking them to delete it.