Summary: This post analyzes the chemical disclosures for a Laramie Energy well pad, comparing data from the legacy FracFocus system against Colorado’s new, more comprehensive ECMC database. The analysis validates that the disclosures are for the same fracking events but confirms the hypothesis that FracFocus reporting is incomplete. While 9 chemicals were shared, the ECMC database listed 11 additional chemicals not found in the FracFocus report. This case study demonstrates the significant gaps in public chemical information when relying solely on FracFocus.
In our post, “Colorado’s New Rules vs. FracFocus: What a Difference Data Makes“, we outlined the major differences between the legacy FracFocus disclosure system and Colorado’s new, more comprehensive ECMC database. We hypothesized that comparing these two data sources for the same fracking job would reveal significant gaps in the public’s access to chemical information if limited solely to FracFocus.
Here, we examine the disclosures for one well pad, the “Hayward 0993-25-09 PAD” operated by Laramie Energy LLC. This post is one in a series of deep dives into individual well pads.
Wellpad details and disclosure links
| Parameter | Value |
|---|---|
| Operator name (in FracFocus): | Laramie Energy LLC |
| Operator name (in ECMC): | LARAMIE ENERGY LLC |
| Wellpad name (in ECMC): | Hayward 0993-25-09 PAD |
| Wellpad ID : | 455725 |
| County: | Mesa |
| Map to wellpad: | Google Map |
| Number of FracFocus wells: | 12 |
| Number of ECMC wells: | 13 |
ECMC disclosure link
FracFocus disclosures
| API Number (and link) | Fracking Start Date |
|---|---|
| 05077105910100 | 2025-03-10 |
| 05077105920000 | 2025-03-10 |
| 05077105930000 | 2025-03-09 |
| 05077105940000 | 2025-03-09 |
| 05077105950000 | 2025-03-17 |
| 05077105970000 | 2025-03-10 |
| 05077106000000 | 2025-03-17 |
| 05077106010000 | 2025-03-17 |
| 05077106020000 | 2025-03-17 |
| 05077106070000 | 2025-03-17 |
Is the Comparison Valid?
Before we analyze the chemicals, we need to confirm 1) that we are looking at the same fracking events in both datasets and 2) that the brand-named products are the same in both datasets.
Details of date comparisons
The figure below show the dates of record for each well in these disclosures. The “spud” date is the first date of drilling. Also shown are the “JobStartDate” for FracFocus disclosures and “Downhole commencement date” for the ECMC disclosures. We use these data to verify that the FracFocus and ECMC disclosures are reporting on the same fracking event.
The fracking chemicals for one well (05-077-10590) have not been disclosed to FracFocus. Otherwise, the ECMC and FracFocus dates align exactly.
Details of product comparisons
We compare the lists of product names to ensure that the fracking chemicals in the disclosures are indeed from the same fracking events.
All product names perfectly match. Water is on the FracFocus list but not the ECMC list (which is typical in many ECMC disclosures).
We conclude that these product names are referring to the same fracking events.
Validation summary:
With the exception of the single missing FracFocus disclosure, the reported start dates and the product names for the operation align. Therefore, we can proceed with a direct comparison of the chemical lists disclosed in each system, keeping that exception in mind. The FracFocus chemical lists have been aggregated to match the pad-level reporting of the ECMC.
The Four Categories of Chemical Data
Our analysis sorts the reported chemical ingredients into four distinct categories. This framework helps us isolate exactly what new information the ECMC system provides and highlights holes in the ECMC disclosures.
Trade Secrets
Trade secrets are only allowed in FracFocus. Because the ECMC data must report all chemicals, we expect any trade secrets in FracFocus to have a corresponding entry in either the “ECMC-only” or the “shared” lists.
No Trade Secrets were reported in these disclosures.
Shared Chemicals
The baseline list of ingredients that are present in both the FracFocus and ECMC disclosures.
Details of shared chemicals
ECMC-Only Chemicals
These are ingredients that appear only in the new ECMC disclosure. These represent the new information, likely including previously unmasked trade secrets and other chemicals not required on a product’s Safety Data Sheet (SDS).
Details of ECMC-Only chemicals
FracFocus-Only Chemicals
These are ingredients that, counter to our hypothesis, might appear only in the FracFocus disclosure. Finding chemicals in this category would be a significant anomaly worth investigating.
Details of FracFocus-Only chemicals
Summary
| Category | Number of materials | Implications |
|---|---|---|
| Trade secrets | 0 | |
| Shared | 9 | |
| ECMC-only | 11 | This list includes several known hazardous materials (acrylamide, methanol, ethylene oxide, formaldehyde) as well as many materials for which little is known about their hazard profiles. This large number of chemicals implies that FracFocus disclosures are woefully incomplete. |
| FracFocus only | 1 | This chemical is unexpected and was used at about 2 tons. The Colorado law clearly stipulates that all materials must be included in the ECMC records. |
Related disclosures:
As of this date, disclosures for 2 other Laramie well pads (355647 and 383264) are similar to the disclosures summarized above in that, they have:
- No trade secrets in FracFocus.
- A long list of chemicals that appear only on the ECMC disclosures, implying a significant deficit in the FracFocus disclosures.
- Zero or one chemicals that should be in ECMC but are not.
We note, however, that these disclosures in both ECMC and FracFocus instruments are remarkably sparse compared to other operators. No sand is reported in either disclosure system and only three products are reported.
Cover art by Becky Mansfield (modified by author)
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