A comparative legal analysis is being conducted of the main regulatory legal acts of the Portuguese Republic and the Russian Federation governing the protection and use of specially protected natural areas. The experience of the Portuguese Republic stands out as innovative and potentially amenable to legal borrowing due to (1) the presence of norms on preserving geo-diversity, (2) the establishment of its own regional networks of specially protected natural areas, (3) the organization of geoparks as a model for managing specially protected natural territories, as well as (4) allowing for the creation of «private protected areas».
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Gulnara F. Batyrshina (2024) studied this question.
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