The JCPOA has several major achievements, especially the long-term restrictions on key aspects of Iran’s declared nuclear program that—if fully implemented, monitored and verified—are likely to prevent Iranian nuclear breakout for up to 15 years. These include the cap on the stockpile of low-enriched uranium for 15 years, the absence of any reprocessing capabilities for this same period, the removal of the core of the Arak plutonium reactor and the monitoring of the core elements of the supply chain for 25 years.

At the same time, we assess that critical aspects of the JCPOA may fall short of the standards outlined in the study group’s June 24 statement. We recommend the following clarifications and additional measures, many of which should appropriately be addressed before Congress votes on the JCPOA.

The June 24 statement outlined five technical parameters for the agreement as well as additional points on deterrence and a “resolute regional strategy”:

1. Monitoring and verification. The agreement meets the study group’s parameters for access to all known sites in Iran, including 24/7 access to declared sites such as Natanz and Fordow. However, we are concerned about whether it provides adequately “timely access” when it comes to undeclared sites. The 24 days allotted to potential delaying tactics by Iran before the issue is transferred for UN Security Council action would probably not permit Iran to hide or scrub sites where nuclear material is being used in illicit fashion. But it may very well make it possible to hide other types of violations, including potential violations of Iran’s commitments in terms of weapons design work, design and manufacture of nonnuclear components used in nuclear weapons, etc. We urge the administration to clarify its plans to address these important issues to ensure the integrity of the JCPOA’s monitoring and verification provisions.
2. Possible military dimensions. Because the precise terms of the IAEA “roadmap” agreement with Iran on this issue are so vague, and because the agreement on access to the Parchin military site has yet to be made public, it is difficult to know whether it meets the terms specified in the study group statement: that IAEA inspectors have the ability “to take samples, to interview scientists and government officials, to inspect sites, and to review and copy documents as required for their investigation.” Further clarification is needed.
3. Advanced centrifuges. In the June 24 statement, the study group called for measures that “preclude the rapid technical upgrade and expansion of Iran’s enrichment capacity after the initial 10-year period.” On this issue, the agreement appears to meet our standard insofar as it stipulates a cap of 300 kilograms on the stockpile of low-enriched uranium that Iran can have for 15 years. At year 10, however, limits on centrifuges begin to be removed, and at year 15, all limits are terminated. While Iran is obligated to share with the IAEA its long-term plan for research and development on centrifuges, that plan is neither public nor binding. Without knowing the content of the plan, it is difficult to judge whether this parameter has been fully met. Given that an essential element of the JCPOA is that Iran has promised “transparency” in exchange for retaining its nuclear infrastructure, we believe it is essential that Iran’s long-term R&D plan be made public soon to allow considered judgment of whether the limitations outlined in the text reflect the intent of the JCPOA.

Read the article in full at the Washington Institute.