It can be attached to whatever you like - the important thing is that you render it.
So you could quite simply use:
$foo['#attached']['css'][] = drupal_get_path('module', 'MODULE') . '/MODULE.css';
drupal_render($foo);
Or stick it in a var like you're already doing:
$variables['SOMETHING']['#attached']['css'][] = drupal_get_path('module', 'MODULE') . '/MODULE.css';
And in the template:
drupal_render($SOMETHING);
It works because drupal_render()
unconditionally calls drupal_process_attached()
on any element it finds with an #attached
property, regardless of what you're doing with the result of the render (or if there's even anything to render).