Baseline Monitoring: creating a "before" and "after" for legal and organizing advocacy

Written by Celia Hawk, Community Democracy Intern, Summer 2026

Baseline monitoring can help community members address concerns about environmental and personal health risks associated with data centers and other industrial development. 

Baseline monitoring helps to: 

  • Create a record that shows a variety of impacts to the environment before, during, and after development to record any potential changes 

  • Collect data for community organizing efforts by showcasing the impacts of industrial development on the area  

  • Potentially help meet a legal burden of proof that an industrial project negatively impacted a community 

Baseline Monitoring helps establish written and visual records of environmental conditions over time. It can take years before a facility is permitted, built, and ready for operations. The time lag makes it difficult to recall pre-construction conditions accurately enough to establish a “before and after” comparison. 

 

Baseline monitoring can help communities to: 

  • Take information to zoning officers and local council members and ask them to hold the polluter accountable through nuisance ordinance or other local law; 

  • Visualize data for social media and community engagement; 

  • Use the information to make complaints to the group that issued the development permit (often the state Department of Environmental Protection or Environmental Protection Agency); 

  • Use the data to get more funding for more “scientific” or “legally admissible” monitoring; 

  • Build monitoring information to leverage to use for a Community Benefits Agreement or Good Neighbor Agreement; 

  • Share information with the media to raise awareness; and 

  • Share the data to help lawyers get a better picture of the case (even if the evidence cannot be directly presented in court). 

Legal Versus Organizing Goals

Legally, baseline monitoring can prove especially helpful in Clean Air, Clean Water, and CERCLA cases, where the burden of proof requires establishing a change in environmental quality from before to after industrial development. However, baseline monitoring for legally admissible evidence must use data collection methods that meet stricter requirements. Data collection technology must be proven to be accurate, and expert testimony must be collected. Therefore, oftentimes professionals, rather than lay people, must conduct baseline monitoring to collect legally admissible records, and these professionals must complete chain of custody forms. Legal monitoring requires time, experts, and funding, so it’s often hard for community groups to do.   

 

How To Monitor for Organizing and Public Pressure

Below are environmental concerns that communities may have regarding construction of data centers and other industrial development, and suggestions about how to conduct baseline monitoring to address those concerns.  

1.Identify the issues you are most concerned about.  There are many environmental and community issues that you can get a baseline on that could help you down the road – air and water quality, water pressure, noise, health, community culture, and costs.  Pick the issues you are most concerned about and focus on those. 

2. See if there are already groups doing this already!  Many Universities, Colleges, environmental non-profits, and community groups already do citizen-science projects.  Collaborating with existing groups can give you access to resources, knowledge, volunteers, and funding that take time to build up on your own.  

3. Build your monitoring group.  There is strength in numbers for baseline monitoring.  Working as part of a larger group of neighbors or in a coalition can provide more resources, capacity, volunteers, and location availability.  If you need to use your monitoring information for a complaint campaign in the future, having more people participating could put more pressure ondecision-makers to take action with the data that you’ve shared.  Think about how you want to structure your group to have clear roles and responsibilities!  Check out Organizing Resources and Tools for more resources on coalition-building. 

Blue boxes with white font.  Font discusses the items that you can include a baseline monitoring journal.

4. Start a journal independently or with a group.  A variety of potential environmental changes can emerge from a new industrial development project which may not be captured within the parameters listed above. A good way to document changes that do not fall into the other categories is through journaling. The journal can be the place where you make your recordings, save photos or videos, and centrally store notes over the months and years. It can be an individual, physical journal, a google form or other online collaborative survey, a shared virtual google doc or a shared and accessible virtual space that everyone can enter information into [note: think about adding password protection to protect your journal from accidental editing, deletion, or sharing without your consent.]. Journal entries can document environmental changes such as; increases in dust and debris, smells, droughts or changes in the local watershed, neighborhood attitudes on the development, and more.

Include in your journal entries: Date, Time , Location, Weather, Things you are seeing (dust, construction, traffic), Things you are hearing (construction, generators), Things you are smelling (unusual odors), How you are feeling, and Timestamped photos and videos.

5. Start Monitoring!  Below are simple and cost-effective ways that you can begin your baseline monitoring work.

What Now?

Overall, baseline monitoring can help to document and prove changes in environmental quality. Community members can opt to start baseline monitoring their environment whether they are concerned about the development of data centers or another form of industry near them. This work has the power to make real changes to protect the environment by educating the public on environmental health concerns and potentially aiding in establishing a burden of proof in a court of law.