Summary: This post compares chemical disclosure data for a Bonanza Creek Energy well pad using the legacy FracFocus system and Colorado’s newer, more comprehensive ECMC database. The analysis confirms the fracking events are the same, but reveals significant differences in chemical reporting. While one trade secret from FracFocus appears to be unmasked in the ECMC data, five other chemicals, which should have been included, are missing from the ECMC disclosure, highlighting gaps in compliance with the new Colorado law.
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.
Here we examine a well pad operated by Bonanza Creek Energy (Antelope O-31) that was representative of several other pads.
Wellpad details and disclosure links
| Parameter | Value |
|---|---|
| Operator name (in FracFocus): | Bonanza Creek Energy, Inc. |
| Operator name (in ECMC): | BONANZA CREEK ENERGY OPERATING COMPANY LLC |
| Wellpad name (in ECMC): | Antelope O-31 |
| Wellpad ID : | 471040 |
| County: | Weld |
| Map to wellpad: | Google Map |
| Number of FracFocus wells: | 5 |
| Number of ECMC wells: | 5 |
ECMC disclosure link
FracFocus disclosures
| API Number (and link) | Fracking Start Date |
|---|---|
| 05123511540000 | 2025-07-23 |
| 05123511560000 | 2025-07-27 |
| 05123511570000 | 2025-07-27 |
| 05123511620000 | 2025-07-27 |
| 05123511630000 | 2025-07-22 |
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 ECMC and FracFocus date 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.
Most product names perfectly match. Mismatches: 1) Water and sand are on the FracFocus list but not the ECMC list (which is typical in many ECMC disclosures). 2) “HYDROCHLORIC ACID, 10-30%” and “DCA-23011” is missing in the ECMC disclosure (a fairly common occurrence). We conclude that these product lists are referring to the same fracking events.
Validation summary:
Because the reported start dates and the product names for the operation largely align, we proceed with a direct comparison of the chemical lists disclosed in each system. 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.
| Ingredient Name | mass (pounds) | Trade Name | number of wells |
|---|---|---|---|
| polyacrylate | 47,944 | Ingredient Container* | 5 |
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 | 1 | |
| Shared | 22 | |
| ECMC-only | 1 | This single material may be the unmasked identity of the trade secret in the FracFocus disclosures. |
| FracFocus only | 5 | This number should be zero. The Colorado law clearly stipulates that all materials must be included in the ECMC records. Some of these may be attributable to the missing product (DCA-23011) in the ECMC disclosure. |
Related disclosures:
As of this date, these other Bonanza well pads are similar to the disclosures summarized above, in that they have only one or zero “ECMC-only” materials, a handful of “FracFocus-only” materials and zero, one or two trade secrets:
| Location ID | Well pad name |
|---|---|
| 429977 | Antelope F-15 PAD |
| 436242 | Pronghorn P-10 PAD |
| 432611 | Pronghorn P-22 PAD |
| 431481 | Pronghorn T-4 PAD |
| 431197 | Pronghorn F-16 PAD |
| 434100 | State Seventy Holes K-3 PAD |
Cover art by Becky Mansfield (modified by author)