Alliance for Clean Coal v. Bayh 72 F.3d 556 (7th Cir. 1995) Due to concern about acid rain, EPA instituted a cap-and-trade system whereby polluters must purchase credits to be allowed to emit SO2 and NOx. The biggest SO2 emitters in the country were coal-burning power plants, because there is a lot of sulfur in most coal. In order to save money, a number of coal-burning power plants started buying low-sulfur coal and shipping it in, as opposed to buying locally-mined high-sulfur coal. A lot of coal mines that produced high sulfur coal began to suffer economically because no one would buy their products.  In response, several States (including Indiana) mandated that their local utilities burn only locally-produced, high-sulfur coal. A number of coal-burning power plants sued Indiana (via Bayh, the Indiana governor) for the right to burn low-sulfur coal. The Trial Court found Indiana's law to be unconstitutional.  Indiana appealed. The Trial Court found that Indiana's law was a violation of the Interstate Commerce Clause. The Appellate Court affirmed. The Appellate Court found that "protection of local, or even regional, industry is simply not a legislative action that is consistent with the Interstate Commerce Clause.