Commission staff told commissioners the third decision point in the clean‑heat rulemaking concerned whether to adopt a rule capping the share of recovered methane that gas utilities may count toward targets.

CDPHE and the Colorado Energy Office recommended that the commission decline to adopt a fixed recovered‑methane cap in the rule and instead preserve commission flexibility to evaluate recovered‑methane proposals in individual clean‑heat plan proceedings. "We conclude the commission has the flexibility and discretion to set firm or flexible recovered methane limits or not to set any limits at all," staff said.

Environmental organizations urged retaining a 5% cap and objected to proposed rule language the groups said could allow utilities to exceed a cap when doing so was deemed "in the public interest." Denver likewise recommended continuing a 5% maximum. Utilities opposed an early numeric cap and urged plan‑level consideration of recovered methane.

Commissioners discussed options including not setting a numeric cap in rule but requiring plan submissions to include a portfolio demonstrating that no more than 5% of reductions would come from recovered methane in any single plan, or crafting decision language and TBC (to be circulated) rule text to manage risk of unreasonable initial proposals. No final rule decision was adopted today; staff and counsel will draft specific rule and decision language for further consideration.

What to watch: The recovered‑methane treatment will determine how quickly utilities can rely on non‑customer electrification resources and may shape market development for recovered methane if the commission chooses an explicit cap or a plan‑level limit.