The Texas Municipal Power Agency is two years ahead of schedule to comply with a state mandate to reduce NOx emissions from its Gibbons Creek power plant to 0.165 lbs/mmBtu or less. Two things are remarkable about TMPA's achievement: NOx was reduced by modifying only the plant's combustion and fuel-delivery systems, and the initiative wasn't structured as a typical EPC project-because the Texas regulator wouldn't allow it.