The CAA allows parties with no standing to sue, to magically have standing to sue, and then have their victims pay lawyers fees (or otherwise go to jail[0]). So there's no need for the EPA to get involved. You can just be sued by, say " Utah Physicians for a Healthy Environment" and end up paying unlimited lawyers fees because some guy 300 miles away says you dropped a particle of carbon on them.

[0] https://www.sltrib.com/news/environment/2025/10/24/after-die...