Análisis documental de expedientes ambientales mediante la metodología de saneamiento en la Subdirección de Sostenibilidad del INVIAS

Abstract

This report presents the results of an internship carried out between February and July 2026 at INVIAS's Sustainability Directorate, applying a document-based methodology for the remediation ("saneamiento") of environmental case files with pending obligations before ANLA, some of them from road projects that have been in operation for over twenty years. As of July 2026, 24 active files, 33 sanction proceedings and a seizure of about COP 581 million were identified. Through 11 visits to ANLA and 16 to the Fontibón Technical Archive, 16 technical diagnoses were produced, 164 environmental requirements were classified (69 in files with no active contract), and 4 draft responses were prepared. The main deliverable was a Requirements and Payments Tracking Matrix, which consolidates requirements, ANLA charges (about COP 4,739 million over twenty years) and sanction proceedings. The study concludes that documentation is the most critical input for remediation, that consulting ANLA must be complemented by reviewing contracts in the Technical Archive, and that the lack of digital records for older projects is the main bottleneck. It recommends formalizing the continuity of the Remediation Group, digitizing physical archives, keeping the matrix up to date, and prioritizing files with precautionary measures or enforced collection proceedings.