is nevertheless discern-able. At least three courts of appeals have held that a public meeting will not serve the public participation requirement unless it is “meaningful.” See Reg’l Airport Auth., 460 F.3d at 708; Union Pac., 215 F.3d at 835, 837-38; Pierson Sand, 1996 WL 338624, at *3-*4 (applying same concept but with different terminology). Although these courts did not specifically state where they derived this “meaningfulness” requirement, it is clear that their goal was to achieve the purposes of the public participation requirement. Cf. 55 Fed.Reg. at 8793 (explaining that “meaningful” public participation is necessary for achieving NCP’s purposes). Other courts have explicitly relied on the purposes of the requirement in reaching their decisions. See Bedford, 156 F.3d at 428 (<HOLDING>); Carson Harbor Village, Ltd. v. Unocal Corp.,
holding that significant involvement of government agency charged with protecting public environmental interest satisfies public participation requirement in certain circumstances holding that public meeting did not satisfy public participation requirement because public did not receive adequate notice recognizing that public utilities affect the public interest in that they render essential public services to a large number of the general public holding that the ncp public participation requirement was fulfilled because the indiana department of environmental management gave public notice and received public comments before issuing an npdes permit for the cleanup even if it did not hold a public hearing holding that significant state involvement satisfies public participation requirement because it serves the identical purpose that the public notice provision seeks to effectuate