When can a pipeline survey land?

A pipeline company wants to build. Accordingly, it sent landowners letters that it would be surveying land.  The Appalachian landowners are unhappy. Rural mountain people upset with big corporations coming onto their land with fancy science equipment reads like a script for Deliverance 2014. 

Lawyers say that until there is an established common carier purpose and a public need, the pipeline cannot survey land. [The Public News Service]

Refreshing Recollection: Earlier this year a California Court disallowed pre-condemnation access to property. Texas Courts are grappling with the same issue. [Legal Trend: Unconstitutional Pre-Condemnation Entry Statutes]