tive resources, although the two frameworks are complementary to an extent. 22 Of particular relevance in this article are obligations relating to energy efficiency standards under the EAEU 23 and the agreement on common electricity markets. 24 While the former can be more complementary to CEPA obligations, the latter would require further legal analysis if Armenia were to trade electricity both with the EU and EAEU. An important nuance is that the country shares no border with any member of the two organisations. All trade will physically take place through a third party, unless a neighbouring country joins one of those organisations as well(as, for instance, both Turkey and Georgia have candidate status in the EU). The potential difficulty is not the trade itself, as multiple countries, e. g., Finland and the Baltic countries, have traded electricity with the EAEU while themselves b eing members of the EU. Rather, it is the question of regulations – whether the sale of electricity to the EU or the EAEU will take place for purely economic reasons (i. e., whoever offers higher prices), or whether there will be restrictions imposed due to Armenia being a member of the EAEU. Another potential question is the role of an intermediary in these regulations; in particular, Georgia, which likewise can have electricity trade with the EAEU (Russia) and, if the Black Sea cable is constructed, with the EU as well. These questions require a legal analysis of electricity market regulations and the potential impact on the management of electricity regimes in Georgia. Georgia Current Energy Mix and Renewable Energy Potential Georgia‘s energy mix is characterised by a high dependence on fossil fuel imports and a notable, though underutilised, potential for renewable energy. In 2023, natural gas domi nated Georgia’s total energy supply, accounting for 51%, fol lowed by oil products at 25% and hydropower at 16.5% 25 . Renewable energy sources, including hydropower, biofuels, and a small contribution from wind and solar, made up approximately 21% of the total supply. Domestic energy production is limited, covering only about 23% of Georgia‘s total energy demand, with the rest being met through imports – especially of natural gas from Azerbaijan and Russia and oil products from various sources. 22 Armenia 2022 Energy Policy Review 23 https://docs.eaeunion.org/upload/iblock/63d/nxgms5og4fb1pouovwz3h9c76d2qzsv9/cncd_24122019_114_doc.pdf 24 https://eec.eaeunion.org/upload/medialibrary/c0d/prilozhenie_21_k_dogovoru_o_eaes.pdf 25 Energy Balance of Georgia 2023 – National Statistics Office of Georgia 8 Friedrich-Ebert-Stiftung e.V.
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Green electricity transitions in Armenia and Georgia : challenges and prospects for regional cooperation
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