Hawaii hotspot created at least 129 volcanoes, more than 123 of which are extinct volcanoes, seamounts, and atolls, four of which are active volcanoes, and two of which are dormant volcanoes. They can be organized into three general categories: the Hawaiian archipelago, which comprises most of the U.S. state of Hawaii and is the location of all modern volcanic activity; the Northwestern Hawaiian Islands, which consist of coral atolls, extinct islands, and atoll islands; and the Emperor Seamounts, all of which have since eroded and subsided to the sea and become seamounts and guyots (flat-topped seamounts). Hawaiian volcanoes are characterized by frequent
Dormant Commerce Clause local government. The dormant Commerce Clause is not a roving license for federal courts to decide what activities are appropriate for state and local government to undertake, and what activities must be the province of private market competition. In this case, the citizens of Oneida and Herkimer Counties have chosen the government to provide waste management services, with a limited role for the private sector in arranging for transport of waste from the curb to the public facilities. The citizens could have left the entire matter for the private sector, in which case any regulation they undertook could not discriminate