Just ahead of a series of public hearings on the petition by Tennessee Gas Pipeline  to conduct surveys along its Northeast Energy Direct pipeline route, the Massachusetts Association of Conservation Commissions has submitted testimony to the state Department of Public Utilities saying it would be premature to force access to more than 400 private properties to conduct surveys for the project.

The DPU has scheduled a hearing at 7 p.m. Wednesday in the Greenfield Middle School auditorium as one of six planned around the state to require landowners along the pipeline route to grant access for civil, archaeological, cultural resources, wetlands and endangered/rare species surveys.

A DPU hearing is also planned for 7 p.m. Monday at Berkshire Community College in Pittsfield, as well as later in Lunenberg, Lynnfield, Dracut and Andover.

The association of conservation commissions rejects the statement by Tennessee Gas that the proposed surveys would be exempt from state Wetlands Protection Act requirements. The association argues, “WPA regulations do not specifically exempt coring and surveying activities from WPA permitting requirements,” although there are some exemptions for coring and surveying under some circumstances in wetland buffer zones, and that local conservation commissions should be the authority determining whether a proposed coring or surveying is exempt or requires its prior approval.

If the DPU does grant the company’s request, the association continues, “we urge DPU to include conditions in each survey order requiring TGP” to serve it on each town’s conservation commission to make the determination, and also offer to meet with the local commission to provide maps, plans and other information about the survey work proposed.

Yet the association argues that ordering surveys on property where the landowner has not granted permission would be premature before the Federal Energy Regulatory Commission completes its environmental review.

The association said the analysis of alternatives as part of that federal review, which is now taking place, could make adjustments in the 64-mile pipeline route through the state, which includes Plainfield in Hampshire County and eight Franklin County towns — Ashfield, Conway, Shelburne, Deerfield, Montague, Erving, Northfield and Warwick.

“In short, the route chosen by TGP, for which it has requested survey orders, is far from final. It may not be the route approved by FERC if it grants a certificate to TGP. … DPU has the authority to grant survey orders preliminary to eminent domain proceedings and thus override a property owner’s power to exclude a survey, but it is not mandated to do so.”

And noting that federal regulations do not require Tennessee Gas to survey, it adds, “DPU should exercise the discretion granted … to prevent unnecessary and premature intrusions on lands where property owners have not authorized TGP to survey. TGP should not be given authority to survey property that may not be on the approved pipeline route.”

Also filing comments with the DPU is Sen. Ann Gobi, D-Spencer, arguing “TGP’s clear motive is to profit off of Massachusetts residents who stand to have their lives disrupted by a new pipeline … There is no noble end goal of such disruption; rather, the end result would let TGP sell the transported gas to liquefied natural gas developers and export it for a profit.”

Gobi added, “The surveys that TGP is proposing are at best intrusive and at worst destructive. The proposals allow TGP to conduct soil probes and digs, cut through vegetation and send employees over the land at will. … TGP seeks permission to conduct highly invasive geotechnical surveys on 23 of the properties, which would allow them to bring in up to four pieces of drilling equipment and create boreholes on the property, all against the wills of property owners.”

Although the company claims that several of the towns, including Deerfield and Conway, that have passed orders prohibiting it from surveying or constructing pipelines within their boundaries, have no authority to prevent them from surveying, “it is abundantly clear that the DPU does have this authority,” writes Gobi. “I would ask you to side with the residents of these towns, and so many others, who clearly feel that the actions of TGP would cause undue harm.”