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На пути к общему электроэнергетическому рынку ЕАЭС: опыт сравнительно-правового анализа
In order to determine the model of international legal regulation of the common electricity market of the Eurasian Economic Union, corresponding to its target characteristics, the article considers the modern experience of integrating the energy systems of States, identifies the main types of existing models of international legal regulation of cooperation for the organization of electricity trade, their main characteristics and legal mechanisms of regulation. According to the results of a comparative study of multilateral associations of States, the models of cooperation in the field of electricity are identified. Based on the analysis of the provisions of the Eurasian Economic Union documents, the author substantiates the thesis that the development of the electric power industry of the Eurasian Economic Union is guided largely by the experience of the European Union, which requires conceptual reform of the electric power industries of some Eurasian Economic Union member States. As a mechanism of «adaptation» of the existing models of the internal electric power markets of the Eurasian Economic Union member States to the target characteristics of the common electricity market, the application of the model of international legal regulation, providing for the regulation of the common electricity market, separate from the national models of electricity trade, is proposed.