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Research into Heritage Impact Assessment (HIA) has criticised the process of Environmental Impact Assessment (EIA) as a tool for protecting cultural heritage, claiming that assessments of impacts on cultural heritage become marginalised and fail to inform key decisions during EIA processes. Many suggestions have been made for optimising the process and providing a platform to improve the understanding of cultural heritage. This article aims to enrich this discussion by challenging established ideas about what constitutes an ‘actor’ in a planning context, arguing that there is a need to expand this term to encompass the bureaucratic production of knowledge and thus to analyse the impact of the production and shape of knowledge on the alleged marginalisation of cultural heritage. This article examines the relevant knowledge production process and the limitations of current practices and in doing so highlights how the knowledge production aspect of an EIA process seems to stabilise cultural heritage as a fact, making it equivalent and comparable to other environmental subjects. A central finding is that this similarity in some cases causes cultural heritage to become invisible in an EIA process, causing it to slip through the net in final decision-making. The empirical starting point for this article is the Norwegian Public Roads Administration (NPRA/ Statens Vegvesen ) and its in-house EIA manual, the Handbook on Impact Analyses (Handbook V712), while the theoretical resources are derived mainly from Science and Technology Studies (STS) and Actor-Network Theory (ANT).

Encountering the machinery of bureaucracy - enacting cultural heritage as facts, maps, and mathematics in environmental impact assessments