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Iran Deal: Section-by-Section Analysis

By Blaise Misztal

Tuesday, July 14, 2015

Preface

The preface of the Joint Comprehensive Plan of Action (JCPOA) contains mostly boilerplate language that resembles what was included in both the interim Joint Plan of Action (JPOA) and the April 2 framework agreement. This key sentence encapsulates both the deal’s structure (nuclear restrictions lifted over time until Iran builds a large-scale nuclear industry) and its central aspiration (that Iran will not misuse the capabilities it will eventually be granted):

  • “[T]he initial mutually determined limitations described in this JCPOA will be followed by a gradual evolution, at a reasonable pace, of Iran’s peaceful nuclear programme, including its enrichment activities, to a commercial programme for exclusively peaceful purposes, consistent with international non-proliferation norms.”

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Preamble and General Provisions

  • Restated commitments by Iran to maintain a peaceful nuclear program, by the P5+1 to the cornerstones of international law, and by all sides to implement this agreement in “good faith” and with “mutual respect.” (Par. i – viii)
  • Interesting addition about “discriminatory regulatory and procedural requirements” not replacing sanctions. Clearly an Iranian concern that sanctions might be continued under a different guise. (Par. viii)
  • Striking inconsistency on how the JCPOA relates to the Treaty on the Non-Proliferation of Nuclear Weapons (NPT): on the one hand, Iran will be treated like any other NPT member; on the other, nothing about how Iran will be treated is a precedent for other NPT members.
    • “the Iranian nuclear programme will be treated in the same manner as that of any other non-nuclear-weapon state party to the NPT.” (Par. iv)
    • “All provisions and measures contained in this JCPOA…should not be considered as setting precedents for any other state…and the rights and obligations under the NPT ….” (Par. xi)
    • This is a tacit admission that:
      1. Iran is being allowed to enrich uranium;
      2. There is no consensus on whether a right to enrich exists in the NPT, although the United States has argued that there is not;
      3. Other countries that have refrained from enrichment due to nonproliferation concerns, such as the United Arab Emirates, will now have reason to demand the same right extended to Iran.
  • A joint P5+1 and Iran Commission will be created to oversee the deal’s implementation, much like under JPOA. (Par. ix) But monitoring compliance will be up to the International Atomic Energy Agency (IAEA), which will report to the United Nations Security Council (UNSC). (Par. x)
  • JCPOA is to be endorsed via UNSC resolution, with no timing provided for the submission of that resolution. (Par. xiv)
    • This resolution would lift all UNSC sanctions the moment the deal goes into effect (“Implementation Day”)
    • It would also set up a process that would effectively graduate Iran from any UNSC supervision (and presumably the possibility of “snap back,” as opposed to newly adopted, UNSC sanctions) 10 years after the resolution is passed (“Adoption Day”).
    • Since there is likely to be a significant difference between when the UNSC passes this resolution and when the deal actually goes into effect, not least because of the U.S. Congress’ 60-day review period, this means that the first major provision of the deal will lapse earlier than 10 years after the deal’s start, more like after 9 and a half years.

I. Nuclear

A. Enrichment, Enrichment R&D, Stockpiles

Par. 1: At least certain limitations on research and development activities (advanced centrifuges?) will only be in place for 8 years. The April 2 framework agreement had stipulated at least a 10-year limitation: “For ten years…enrichment research and development will be limited….”

Par. 2: For 10 years, no more than 5,060 IR-1 centrifuges at the Natanz Fuel Enrichment Plant. This means Iran will be able to produce roughly 1,400 – 2,000 kilograms of 3.5 percent enriched uranium hexafluoride (UF6, the gaseous form of uranium used for enrichment) per year.

Additional centrifuges (there are currently some 16,500 at Natanz FEP) “will be stored under IAEA continuous monitoring.” No details yet on where they will stored (at Natanz, offsite, out of country?) and in what state (disconnected, disassembled?). Moreover, “Iran will begin phasing out its IR-1 centrifuges in 10 years.” This seemingly not just allows but endorses Iran to move the entirety of its enrichment to much faster next generation centrifuges in the next decade.

Par. 3: Research and design on advanced centrifuges allowed to continue during the initial 10-year period, but with no stockpiling allowed of enriched uranium produced in those centrifuges. R&D allowed to proceed on IR-4, IR-5, IR-6 and IR-8 models (no mention of IR-2?), but the latter two can only be tested in significant quantities after eight-and-a-half years (per Par. 1?).

Par. 4: Iran will be able to replace IR-1 centrifuges with new machines of the same model throughout the deal. By year eight, however, Iran will be permitted to begin building and stockpiling IR-6 and IR-8 centrifuges for eventual installation and use in its enrichment facilities. This will effectively give it a “surge capacity” of advanced centrifuges as soon as the deal’s initial period ends.

Par. 5: For 15 years, any uranium enrichment will happen only at Natanz FEP. No enrichment above 3.67 percent. No uranium enrichment or uranium enrichment R&D at Fordow FEP during this period.

Par. 6: Iran will be permitted to have 1,044 centrifuges installed at Fordow (out of some 2,700 currently). Of these, 348 will be used for R&D and enriching materials other than uranium. The remaining 696 will remain installed, but idle.

Par. 7: For 15 years, maximum nuclear material stockpile will be 300 kilograms of UF6 enriched up to 3.67 percent. Excess produced UF6 will be sold on the world market in return for natural (unenriched) uranium or diluted back into an unenriched state. The fuel rods for use in Iran’s reactors, whether domestically produced or imported from abroad, will not be counted against this total.

This means that, at any given time, Iran is likely to have more than the equivalent of 300 kg of 3.5 percent enriched UF6. First, if it will be exporting UF6 it will first have to produce and accumulate enough of it to ship abroad in commercially viable quantities. During this period of time, its stockpile would exceed the 300 kg limit. Second, because the enriched uranium contained in fuel rods could be extracted and converted back into UF6, the actual amount of enriched material available to Iran for a breakout, if it were to pursue one, would exceed 300 kilograms.

B. Arak, Heavy Water, Reprocessing

Par. 8: The heavy water reactor at Arak, which is not yet operational but, in its current form, would produce plutonium that could be used in a nuclear device, will be redesigned to no longer produce plutonium. To further limit proliferation risks from Arak, all spent fuel from the reactor will be shipped overseas, to a country of Iran’s choosing.

Par. 9: Iran will look to light water reactors (like the current one at Bushehr, which constitute a lower proliferation risk than heavy water reactors) to meet its future nuclear energy needs.

Par. 10: Iran will not build more heavy water reactors or produce more heavy water.

Par. 11: All spent nuclear fuel (to include Bushehr and Tehran Research Reactors?) will be shipped abroad.

Par. 12: Iran will not engage in spent fuel reprocessing or R&D into such activities for 15 years. Also, it “does not intend to thereafter,” but if it decided to do so, that would presumably be allowed by the terms of the deal.

C. Transparency and Confidence Building Measures

Par. 13: Iran will at first voluntarily submit to the enhanced IAEA verification measures known as the Additional Protocol. It will eventually submit the Additional Protocol for acceptance by the Majlis and officially sign on to both it and another measure known as the modified Code 3.1 of the Safeguard Agreement. By agreeing to these measures Iran would give IAEA inspectors greater access to its nuclear facilities as well as pledge to give them more advance notice in case of the construction of new facilities.

Par. 14: Iran pledges to answer all outstanding questions the IAEA has about the possible military dimension (PMD) of Iran’s nuclear program and research by October 15, 2015. The IAEA would issue its assessment of these answers by December 15, 2015, followed by the P5+1 moving to close the IAEA’s scrutiny of Iran on this score.

There is no indication given here of whether there are any consequences for Iran failing to meet the October 15 deadline, for the IAEA judging its answers not to be satisfactory, or for any revelation that it did engage in nuclear weapons research much longer than originally suspected.

Par. 15: Iran accepts IAEA monitoring to include:

  • a long-term IAEA presence in Iran
  • IAEA monitoring of uranium ore produced by Iran for 25 years
  • surveillance of centrifuge construction for 20 years
  • a reliable mechanism to ensure speedy resolution of IAEA access concerns for 15 years.

Par. 16: Iran will not engage in research aimed at constructing a nuclear weapon.

Par. 17: Iran will procure nuclear-related technology and parts through a U.N.-established channel.

D. Sanctions

Par. 18: All UNSC resolutions (1969, 1737, 1747, 1803, 1835, 1929, 2224) will be terminated at the moment that the IAEA verifies Iranian implementation of the deal.

Par. 19: The European Union will terminate all of its nuclear-related sanctions at the moment that the IAEA verifies Iranian implementation of the deal. These include, among others:

  • Transfers of funds between EU entities and Iranian entities
  • Banking activities, including the opening of new branches of Iranian banks in the territories of EU member states
  • Supply of specialized financial messaging services, including SWIFT, for certain Iranian financial institutions, including for the Central Bank of Iran
  • Financial support for trade with Iran (export credit, guarantees or insurance)
  • Import and transport of Iranian oil, petroleum products, gas and petrochemical products
  • Export of key equipment or technology for the oil, gas and petrochemical sectors
  • Investment in the oil, gas and petrochemical sectors
  • Export of key naval equipment and technology

Par. 20: EU will terminate all proliferation-related sanctions on Iran no later than eight years after the deal is adopted.

Par. 21: The United States will suspend enforcement of relevant sanctions at the moment that the IAEA verifies Iranian implementation of the deal. These include, among others:

  • Financial and banking transactions with Iranian banks, including the Central Bank of Iran
  • Transactions in Iranian Rial
  • Bilateral limitations on international transfer of Iranian revenues
  • Financial messaging services to the Central Bank of Iran and Iranian financial institutions
  • Efforts to reduce Iran’s crude oil sales
  • Investment in Iran’s oil, gas and petrochemical sectors
  • Purchase of petroleum, petrochemical products and natural gas from Iran
  • Export of refined petroleum products and petrochemical products to Iran
  • Transactions with Iran’s energy sector

Moreover, the president will terminate Executive Orders 13574, 13590, 13622 and 13645, as well as parts of 13628.

Par. 22: The United States will allow for sale of commercial aircraft, parts and service to Iran.

Par. 23: No later than eight years after the deal’s adoption, the United States will terminate all sanctions on Iran prohibiting it from important sensitive nuclear technology.

Par. 24: Once the deal is implemented, Iran will be able to flag any sanction that remains in place that it believes should be lifted under the terms of the deal. The issue would then be sent to the Joint Commission for resolution.

Par. 25: The U.S. federal government agrees to seek to change any state or local law that might be seen as preventing the full lifting of sanctions under the terms of the deal.

Par. 26: The EU and UNSC will not re-impose previous, nor pass any new nuclear-related sanctions on Iran. The United States (presumably meaning the executive branch) will “make best efforts in good faith…to prevent interference with the realisation of the full benefit by Iran of the sanctions lifting.” Iran will treat any re-imposition of lifted sanctions or imposition of new nuclear-related sanctions as a reason to stop complying with the deal.

Par. 27: The EU and United States will offer public, regulatory guidance about which sanctions have been lifted, presumably to facilitate and speed the flow of international business to Iran.

Par. 28: All parties commit to implement the agreement in good faith and even: “Senior Government officials…will make every effort to support the successful implementation of this JCPOA including in their public statements.” Interesting to see if this will apply to Iranian Supreme Leader Ali Khamenei, or whether he does not qualify as a “senior government official.”

Par. 29: The EU and United States will not try to impede normalization of trade ties by any other means.

Par. 30: No one can be sanctioned or charged for doing business with Iran pursuant to the newly-lifted sanctions.

Par. 31: The EU and United States will remove certain Iranian entities and persons, including the Central Bank of Iran, from their list of designated (i.e. sanctioned) entities.

Par. 32: The P5+1 will cooperate with and help Iran develop a peaceful, civilian nuclear energy program.

Par. 33: The EU will provide government assistance, such as financing, to promote trade with Iran. The United States is not included in this provision, presumably because of the political difficulties facing the Export-Import Bank.

II. Implementation Plan

Par. 34: A basic timeline for each side implementing the deal:

  • “Finalisation Day:” July 14, 2015. To be followed shortly thereafter by a UNSC resolution endorsing the deal
  • “Adoption Day:” 90 days later (October 12, 2015). JCPOA commitments go into effect. Note that is likely before Iran has to address all PMD questions
  • “Implementation Day:” when the IAEA judges all sides have implemented preliminary measures, no concrete date specified
  • “Transition Day:” eight years after Adoption Day, or earlier if allowed by IAEA. Further lifting of sanctions and relaxation of additional nuclear restrictions on Iran
  • “Termination Day:” 10 years after Adoption Day. All UNSC resolutions are terminated, EU lifts further sanctions

III. Dispute Resolution Mechanism

Par. 36: Both Iran and the P5+1 can refer each other to the Joint Commission if either side is believed not to be holding up its end of the deal. This process would look as follows:

  • The Joint Commission will have 15 days to address the issue
  • If still not satisfactorily resolved, issue can be elevated to Ministers of Foreign Affairs (MFA)
  • This group would then again have 15 days to address
  • Additionally, either party can ask that the issue be referred to an arbitration-like Advisory Board that would have 15 days to offer a non-binding opinion
  • If still unresolved after 30 days (so Commission review followed by either or both MFA or Advisory Board review), the issue would go back to the Commission for another five days
  • If the issue still remains unsatisfactorily resolved, the complaining party has the option of deeming that the JCPOA is not being complied with, notifying the UNSC of this, and effectively leaving the deal

Par. 37: Once informed that the above process has failed to reach a successful conclusion, the UNSC would take up the issue. This process would look as follows:

  • UNSC votes on a resolution to continue lifting sanctions
  • If the resolution fails or is not passed within 30 days, UNSC sanctions are reimposed

However, Iran indicates that any such reimposition of UNSC sanctions would lead it to cease complying with the deal.

Annex I: Nuclear-related Measures

A. General

Par. 1: Schedule of implementing below measures is contained in Annex V.

B. Arak Heavy Water Research Reactor

Par. 2: The Arak reactor will be redesigned, with assistance from the P5+1, to minimize the production of plutonium. The total power output of the redesigned facility will be lowered from the planned 40 megawatts to 20 MW.

Par: 3: Iran will not continue construction of the Arak reactor using the current design and will remove and render the reactor core (known as a “calandria”) inoperable by filling it with concrete.

Par. 4: The P5+1 and possibly additional countries will work with Iran to come up with and implement the new design.

Par. 5: The Joint Commission will review and endorse the design plans. Failure to do so within three months would be grounds for Iran beginning the dispute resolution process.

Par. 6: The IAEA will monitor construction and verify the final facility.

Par. 7 and 8: The P5+1 will allow and facilitate the purchase by Iran of any new equipment needed to construct the redesigned Arak reactor.

Par. 9: The redesigned reactor will use 3.5 percent enriched uranium for fuel (as opposed to the natural uranium commonly used to fuel heavy water reactors). Other countries will help Iran develop this fuel, after which it will be produced domestically.

Par. 10: Iran will not use any of the existing fuel it had developed for the Arak reactor and will store and eventually dispose of it.

Par. 11: Iran will ship all spent nuclear fuel from Arak abroad, to either a P5+1 country or another country of its choosing within one year of the fuel being removed from the reactor.

Par. 12: Iran will provide the IAEA with updated plans for the redesigned Arak reactor.

Par. 13: Iran’s Fuel Manufacturing Plant will only produce fuel for the redesigned Arak reactor (and not for the previous design).

C. Heavy Water Production Plant 

Par. 14: The heavy water Iran has already produced for use in the previous design of the Arak reactor, and that is not needed for other purposes such as medical research, will be sold on the international market “and delivered…for 15 years.” This seems to suggest Iran will be in possession of its heavy water stocks for the duration of the deal. The amount of heavy water that Iran needs to retain is judged to be 220 metric tons.

Par. 15: The IAEA will be allowed to monitor the Heavy Water Production Plant (HWPP), which appears to remain operable under the terms of the deal. Previous IAEA estimates suggested the HWPP was capable of producing 16 metric tons of heavy water annually.

D. Other Reactors

Par. 16: Iran will use light water reactors for its future nuclear energy needs.

Par. 17: Iran will ship all spent nuclear fuel from all future reactors abroad to a yet to be determined third country.

E. Spent Fuel Reprocessing Activities 

Par. 18 – 21: Iran will not engage in spent fuel reprocessing (which can extract plutonium for use in a nuclear weapon), other than for research and medical purposes, for at least 15 years.

Par. 22 – 23: P5+1 countries will make their facilities available to Iran for certain types of experimentation having to do with optimizing fuel composition for reactors. Iran will be allowed to do some similar testing itself, but only at the Arak facility under certain conditions.

Par. 24: For 15 years, Iran will not research, acquire, or experiment with plutonium or uranium metals, the machining and shaping of which is a critical step in producing the fissile core of a nuclear weapon.

Par. 25: For 15 years, Iran will not produce or acquire plutonium or highly-enriched uranium, the fissile material needed for a nuclear weapon.

Par. 26: After 10 years, Iran can seek permission from the Joint Commission to use uranium metal as a fuel for the Tehran Research Reactor.

F. Enrichment Capability 

Par. 27: For 10 years, Iran will not operate or install more than 5,060 IR-1 centrifuges at the Natanz FEP.

Par. 28: For 15 years, Iran will not enrich uranium above 3.67 percent.

Par. 29: All excess centrifuges at the Natanz FEP (about 11,000) will be removed and stored in Hall B of the same facility (a non-operational wing of this underground facility) under continuous monitoring. This includes the 1,000 advanced IR-2m centrifuges currently installed at Natanz FEP as well as additional, unused centrifuge infrastructure (piping, valves, pressure transducers and frequency inverters. The stored IR-1 centrifuges can be used as spares to replace any of the permitted 5,060 machines that fail.

Iran’s spare centrifuges will thus be stored only feet away from where they would have to be reinstalled, making a potential breakout much easier, even if detectable. Nor is it clear if they will be fully disassembled or stored as complete machines ready for reinstallation. 

Par. 30: The IAEA will inspect all centrifuges being replaced.

Par. 31: For 15 years, Iran will be limited by the conditions of this deal as to in which facilities it can install centrifuges (i.e. no new centrifuge plants).

G. Centrifuge Research and Development

Par. 32: For 10 years, the R&D Iran can conduct on advanced centrifuges will be limited under the following conditions:

  • Iran can enrich uranium, but dilute (not store) the final product, using IR-4, IR-5, IR-6, and IR-8 centrifuges
  • Iran can test the mechanisms of, but not enrich uranium in, not more than two of IR-2m, IR-4, IR-5, IR-6, IR-6s, IR-7, and IR-8 centrifuges

Par. 33 – 34: By the time the deal is implemented, Iran will have dismantled the 164 IR-2m and 164 IR-4 centrifuges currently operating at the Natanz Pilot Fuel Enrichment Plant (PFEP) R&D facility and store them underground, in Hall B, along with the other excess centrifuges from Natanz.

Par. 35 – 36: For the first 10 years, Iran can test up to 10 IR-4 centrifuges and a single IR-5 at once.

Par. 37 – 38: After eight and a half years, Iran can ramp up from testing a smaller number of IR-6 and IR-8 centrifuges to running as many as 30 of each.

Par. 39: For 10 years, the IR-6 and IR-8 centrifuges will be set up in such a way that whatever enriched uranium they produce is automatically diluted back to a natural level.

Par. 40: For 15 years, all enrichment R&D with advanced centrifuges will occur at the Natanz PFEP.

Par. 41: Iran will remove all excess centrifuges and related equipment from the Natanz PFEP, including 328 IR-1 centrifuges from Cascade 6, and store them in Hall B of the Natanz FEP. The 328 IR-1 centrifuges from Cascade 1 will remain in place, but be rendered inoperable by injecting an epoxy into the centrifuge cylinder.

Par. 42: The Natanz PFEP will be updated to prepare it for the type of centrifuge R&D permitted under the deal.

Par. 43: Iran will be allowed to conduct computer modelling and simulations of new centrifuge models (beyond those specified above) at its universities. However, if it intends to build a functional prototype of any such new design within the first 10 years, it would need approval from the Joint Commission.

H. Fordow Fuel Enrichment Plant

Par. 44: Fordow will be converted into an international research and collaboration center.

Par. 45: No uranium enrichment will take place there for 15 years.

Par. 46: For those 15 years, no more than 1,044 IR-1 centrifuges can be installed at Fordow (there are currently 2,710 IR-1 centrifuges there, of which 696 have been used for enrichment).

  • The 348 (out of the 1,044 allowed) centrifuges that had not previously enriched uranium will be adapted for enrichment of other (non-nuclear) materials
  • Another 348 centrifuges (half of those used for uranium enrichment) will be immediately turned off, but left intact
  • The final 348 centrifuges will continue enriching until the first set is ready to begin non-nuclear enrichment, at which point they will be turned off, but left installed

Par. 47 – 48: All excess centrifuges and related equipment will be removed from Fordow and stored in Hall B at Natanz FEP.

Par. 49: The 696 idle centrifuges at Fordow can be used as spares for the operating machines.

Par. 50: For 15 years, Iran will not use more than 348 centrifuges for its non-nuclear enrichment activities at Fordow.

Par. 51: The IAEA will allow some enriched uranium to remain at Fordow (quantity unspecified). Iran will grant the IAEA daily access to Fordow for 15 years.

I. Other Aspects of Enrichment

Par. 52: The IAEA will confirm that Iran is abiding by R&D restrictions.

Par. 53: After 10 years, Iran will begin to install infrastructure for housing IR-8 centrifuges in Hall B of Natanz FEP.

Par. 54 – 55: There needs to be an agreed to classification and performance measuring scheme for Iran’s advanced centrifuges.

J. Uranium Stocks and Fuel

Par. 56: For 15 years, Iran will not exceed a stockpile of 300 kilograms of 3.67 percent enriched UF6.

Par. 57: Iran can sell any excess amount of enriched UF6 on the international market in return for natural uranium.

Par. 58: All existing uranium oxide that has been produced under the JPOA (including enrichment levels of 3.5 and 20 percent) will be turned into reactor fuel, shipped abroad, diluted, or disposed of.

Par. 59: Fuel assemblies supplied by Russia for the Bushehr reactor do not count against the 300 kg limit. Same goes for any outside fuel for Arak. The Joint Commission will have to establish a mechanism for how to account for excess enriched UF6 that Iran is turning into nuclear fuel domestically and for ensuring that any nuclear fuel is not converted back into UF6.

Par. 60: Iran will attempt to buy fuel for the Tehran Research Reactor (which uses 20 percent enriched uranium) on the international market or be provided such fuel by the P5+1. Iran will not be allowed to acquire more than 5 kilograms of this fuel at a time and not until it proves that all previous fuel is being used.

K. Centrifuge Manufacturing

Par. 61: Iran will not build centrifuges beyond that needed for its enrichment and R&D plans as stipulated in the deal.

Par. 62: Iran will use its stored IR-1 centrifuges to replace any of the 5,060 operating IR-1 centrifuges that fail. If that stock falls below 500 machines, Iran can produce additional IR-1 centrifuges so long as the total stockpile does not exceed 500 machines.

Par. 63: After year eight, Iran will begin producing 200 IR-6 and IR-8 centrifuges a year. These machines will initially be incomplete (missing rotors). After year 10, Iran will produce complete machines at the same rate. They will be stored above-ground at Natanz until ready to install.

L. Additional Protocol and Modified Code 3.1

Par. 64: Iran will provisionally abide by the Additional Protocol until it can be adopted by the Majlis.

Par. 65: Iran will implement the Modified Code 3.1 to its Safeguards Agreement with the IAEA.

M. Past and Present Issues of Concern

Par. 66: Iran will address lingering concerns about possible military dimensions of its nuclear program by carrying out the activities stipulated in the “Roadmap for Clarification of Past and Present Outstanding Issues,” which IAEA just signed with Iran.

N. Modern Technologies and Long term Presence of IAEA

Par. 67: For 15 years, Iran will permit the IAEA the use of the advanced monitoring technology and techniques that allow for real-time monitoring as well as networked and automated data collection. Iran will also allow up to 150 IAEA inspectors to be in the country, including Americans (which it has previously blocked), and accept their long-term presence.

O. Transparency Related to Uranium Ore Concentrate (UOC)

Par. 68 – 69: For 25 years, the IAEA will monitor the use of all uranium ore, to ensure it is not being diverted to covert facilities.

P. Transparency Related to Enrichment

Par. 70 – 73: For 15 years:

  • All enrichment will only take place at Natanz
  • The IAEA will have daily access to all buildings at Natanz
  • The IAEA will continuously monitor all excess centrifuges stored at Natanz
  • Iran will only be allowed to export enrichment technology with permission of the Joint Commission

Q. Access

Par. 74: The IAEA will only conduct the “minimum necessary” inspections.

Par. 75: If the IAEA has concerns about a facility that has not been previously agreed upon for inspections, it will have to first raise its concerns with Iran.

Par. 76: Iran will respond to the IAEA’s concerns and, if still unsatisfied, the IAEA can request access to the facility in question.

Par. 77: Iran may then propose “alternative means” to resolve IAEA concerns, rather than allowing access.

Par. 78: If the IAEA is still not satisfied with Iran’s response within 14 days of the original request for access, the issue can be taken to the Joint Commission. The Commission would have seven days to determine a resolution that at least a majority of members agree to. Iran would then have to take any action recommended by the Commission within three days. This means that 24 days could pass between when the IAEA requests access to a suspect site and when it can be let in.

R. Centrifuge Component Manufacturing Transparency

Par. 79 – 80: For 20 years, the IAEA will monitor Iranian production of critical centrifuge parts (rotors and bellows).

S. Other Uranium Isotope Separation Activities

Par. 81: For 10 years, Iran will not be allowed use any form of uranium enrichment besides gas centrifuges.

T. Activities Which Could Contribute to the Design and Development of a Nuclear Explosive Device

Par. 82: Iran will be restricted from the following activities:

  • Using computer models to simulate nuclear explosive devices
  • Researching or acquiring detonation systems that could be used with nuclear explosive devices

Annex II: Sanctions-related commitments 

A. European Union 

EU member states will terminate all nuclear-related sanctions on Iran, including:

  • Financial, banking, and insurance measures
  • Oil, gas, and petrochemical sectors
  • Shipping, shipbuilding, and transport sectors
  • Gold, other precious metals, banknotes and coinage
  • Nuclear-proliferation measures
  • Metals
  • Software
  • Arms
  • Certain persons, entities, and bodies.

B. United States 

The United States agrees to “cease the application of, and to seek such legislative action as may be appropriate to terminate” all nuclear-related sanctions, including:

  • Financial and banking measures
  • Insurance measures
  • Energy and petrochemical sectors
  • Shipping, shipbuilding and port sectors
  • Gold and other precious metals
  • Software and metals
  • Automotive sector
  • Nuclear proliferation-related measures

Annex III: Civil Nuclear Cooperation 

A. General 

Par. 1 – 3: The P5+1 and IAEA can cooperate with Iran in development of civil nuclear projects.

B. Reactors, Fuels and Associated Technologies, Facilities, and Processes 

Par. 4: P5+1 countries will help Iran acquire modern light water reactors for electricity production and research, including assistance in construction, obtaining control systems and other equipment, necessary software, and personnel training.

Par. 5: P5+1 countries will help Iran redesign and implement changes to the Arak Heavy Water reactor.

Par. 6: P5+1 will help Iran develop nuclear fuel that is of sufficient quality and with necessary licenses for international export.

C. Research and Development Practices

Par. 7: P5+1 countries will cooperate with Iran acquiring the following nuclear technologies:

  • Accelerator-based nuclear physics
  • Plasma physics and nuclear fusion
  • Research reactor applications

D. Nuclear Safety, Safeguards, and Security 

Par. 8: P5+1 countries will help Iran establish a Nuclear Safety Centre to train and provide support to Iranian regulatory authorities.

Par. 9: P5+1 countries will help train Iran on how to more effectively implement IAEA safeguards measures.

Par. 10: P5+1 countries will help train Iran on how to ensure the safety of its nuclear facilities, including against sabotage.

E. Nuclear Medicine and Radioisotopes, Associated Technologies, Facilities, and Processes 

Par. 11: P5+1 countries will help Iran improve its use of nuclear medicine, including imaging and radiation therapy.

F. Waste Management and Facility Decommissioning 

Par. 12 – 15: P5+1 countries will help Iran dispose of nuclear waste as well as decontaminate and decommission nuclear facilities.

G. Other Projects

Par. 16: Other areas of cooperation between Iran and P5+1 could include nuclear desalinization and medical laser technology.

Annex IV: Joint Commission 

Par. 1:

  • The Joint Commission is composed of:
    • United States
    • China
    • France
    • Germany
    • Russia
    • United Kingdom
    • EU High Representative for Foreign Affairs
    • Iran
  • The High Representative will serve as Commissioner
  • Smaller Working Groups can be established as necessary

Par. 2: the Commission’s functions include:

  • Reviewing and approving designs and plans for updated or new facilities under the JCPOA
  • Approving of and assisting Iran’s nuclear fuel and enrichment technology exports
  • Reviewing issues resulting from implementation of sanctions relief
  • Reviewing claims of noncompliance by any member of the Commission

Par. 3: Procedures for Commission meetings include:

  • The Commission will meet quarterly or as requested by a member
  • Once a member requests a meeting, it must be held within one week, unless dealing with inspections access issues, in which case it should be sooner
  • Meetings will be held in New York, Geneva, or Vienna
  • The work of the Joint Commission is confidential

Par. 4: Decision-making in the Commission is:

  • By consensus
  • One vote per member
  • Votes are recorded (not anonymous)
  • Issues related to inspections access need at least five votes

Par. 5: Members cover their own costs to participate.

Par. 6: The Joint Commission will establish a Procurement Working Group with the purpose of reviewing proposals from states seeking to provide Iran with nuclear technology and equipment. The Group will report its decisions to the UNSC regularly.

Par. 7: The Joint Commission will establish a Working Group on Implementation of Sanctions Lifting to oversee this aspect of the deal. Iran can refer any Commission member that it believes is not fully lifting sanctions first to the Working Group and, if there is no resolution after 30 days, to the full Commission.

Annex V: Implementation Plan 

A. Finalisation Day 

Par. 2 – 5: Upon reaching this deal, the P5+1 countries and Iran will:

  • Endorse the deal
  • Submit a resolution to the UNSC “without delay”
  • Begin making arrangements for implementation of the transparency measures together with IAEA

B. Adoption Day 

Par. 6: Adoption Day occurs 90 days after the UNSC passes the above resolution endorsing the deal (around October 12, 2015, assuming the UNSC acts shortly after July 14).

Par. 7: On Adoption Day the P5+1 will begin preparations to implement the deal.

Par. 8: On Adoption Day, Iran will notify the IAEA that it will begin voluntarily abiding by the Additional Protocol by Implementation Day.

Par. 9: Iran will complete required activities related to the “Roadmap on Past and Present Issues of Concern.”

Par. 10: EU countries will adopt a regulation terminating relevant sanctions as of Implementation Day.

Par. 11: The United States will issue waivers of relevant sanctions to take effect on Implementation Day as well as terminating relevant Executive Orders.

Par. 12: Negotiations will begin on document stating P5+1 commitment to modernizing Arak heavy water reactor.

Par. 13: The EU and United States will begin work with Iran on public guidance on lifted sanctions.

C. Implementation Day 

Par. 14 – 18: Implementation Day will take place once the IAEA verifies that:

  • Iran implements transparency measures related to Arak, enrichment, centrifuge R&D, uranium stockpile, and the Additional Protocol
  • The European Union terminates relevant nuclear-related sanctions
  • The United States ceases the application of relevant nuclear-related sanctions
  • The UNSC lifts all its sanctions on Iran, though they remain subject to reimposition

D. Transition Day 

Par. 19 – 22: Transition Day occurs no later than eight years after Adoption Day or as soon as the IAEA and UNSC determine that “all nuclear material in Iran remains in peaceful activities.” On or by this date:

  • The EU will terminate additional sanctions
  • The United States will seek legislation to terminate all sanctions only waived by executive authority
  • Iran will ratify the Additional Protocol

E. UNSCR Termination Day

Par. 23: Termination Day occurs 10 years after Adoption Day.

Par. 24: On Termination Day, UNSC and EU sanctions on Iran are fully lifted and can no longer be reimposed or snapped back.

KEYWORDS: INTERNATIONAL ATOMIC ENERGY AGENCY, IRAN, JOINT PLAN OF ACTION, NUCLEAR WEAPONS, P5+1 COUNTRIES