The JCPOA was never meant to be verified.
That's the only logical conclusion.
Else it would have contained explicit provisions for permitting access to military facilities. After all, the JCPOA is about the militarisation of nuclear technology.
As it stands, the JCPOA arbitration mechanism provides room for Iran to deny physical access to military sites by IAEA inspectors, by relying on the voting mechanism of the Joint Commission.
Else it never would have contained a clause that placed Iranian military sites off limits to verification - especially given that at least one of the sites was, as you've posted, already known to be a nuclear research facility.
There's actually been a lot written about what seems might be the actual point of the JCPOA: its goal seems to have been to get the US out of being involved in the Middle East by ceding power to Iran.
If the actual goal of the JCPOA was not to stop the Iranian nuclear program but was to get the US out of the Middle East. then verification of Iranian compliance with the JCPOA's "anti-nuclear proliferation" provisions (for lack of a better term) was not really all that important.
Getting the US out of the Middle East seems like a laudable goal. Turning it over to Iran? Maybe not so much.
Senator Chuck Schumer wrote this:
In the first ten years of the deal, there are serious weaknesses in the agreement. First, inspections are not “anywhere, anytime”; the 24-day delay before we can inspect is troubling. While inspectors would likely be able to detect radioactive isotopes at a site after 24 days, that delay would enable Iran to escape detection of any illicit building and improving of possible military dimensions (PMD) – the tools that go into building a bomb but don’t emit radioactivity.
Furthermore, even when we detect radioactivity at a site where Iran is illicitly advancing its bomb-making capability, the 24-day delay would hinder our ability to determine precisely what was being done at that site.
Even more troubling is the fact that the U.S. cannot demand inspections unilaterally. By requiring the majority of the 8-member Joint Commission, and assuming that China, Russia, and Iran will not cooperate, inspections would require the votes of all three European members of the P5+1 as well as the EU representative. It is reasonable to fear that, once the Europeans become entangled in lucrative economic relations with Iran, they may well be inclined not to rock the boat by voting to allow inspections.
When it comes to the non-nuclear aspects of the deal, I think there is a strong case that we are better off without an agreement than with one.
To me, the very real risk that Iran will not moderate and will, instead, use the agreement to pursue its nefarious goals is too great.
That's from Chuck Schumer, hardly any fan of President Trump.
That doesn't sound like the description of any agreement actually meant to have compliance verified. In fact, it seems like the JCPOA was designed to make actual compliance verification effectively impossible.
If the JCPOA were meant to be verified, why did it reportedly have "secret loopholes"?
U.S., others agreed 'secret' exemptions for Iran after nuclear deal: think tank
The United States and its negotiating partners agreed “in secret” to allow Iran to evade some restrictions in last year’s landmark nuclear agreement in order to meet the deadline for it to start getting relief from economic sanctions, according to a think tank report published on Thursday.
That's consistent with a JCPOA actual goal of allowing the US to withdraw from the Middle East.
Furthermore, from 2015 we have this, which explicitly claims that the goal of the JCPOA was not to stop Iran's nuclear weapons program but to allow the US to disengage from the Middle East:
Obama Strikes a Deal--With Qassem Suleimani
According to the terms of the Iran deal announced in Vienna on Tuesday, U.N. Security Council sanctions regarding nuclear-related issues will be lifted on a number of entities and individuals—from Iranian banks to Lebanese assassins, like Anis Nacacche. The name that most sticks out is IRGC-Quds Force commander Qassem Suleimani. Administration officials counsel calm, and explain that Suleimani is still on the U.S. terror list and will remain on the terror list. But that’s irrelevant. The reality is that Suleimani is the key to the Joint Comprehensive Plan of Action.
The White House’s so-called nuclear talks with Iran over the last 18 months were never about Iran’s nuclear weapons program. ...
The negotiations were about something else entirely—they were about what Obama has described as a new geopolitical equilibrium, which would stabilize the Middle East and allow the administration to further minimize its role in the region. The way Obama described it publicly, this new security architecture was going to balance Iran against traditional American allies, like Saudi Arabia. However, it soon became apparent that the White House wasn’t really balancing at all, but had rather chosen one team over the others, Iran.
So the goal was to disengage the US from the Middle East entirely, while not leaving a power vacuum/failed state situation as in Libya. Iran would stabilize the Middle East.
Else why would the US look the other way about how the money Iran would get would go towards funding terrorism. Because the Obama administration knew some of the money Iran got from the JCPOA would fund terrorism:
John Kerry: Some sanctions relief money for Iran will go to terrorism
Secretary of State John Kerry acknowledged to CNBC Thursday that some of the money Iran received in sanctions relief would go to groups considered terrorists.
Note that was reported when it happened back in 2015-2016. The Obama administration knew but pushed forward with the JCPOA anyway. I assume the calculation was that any terrorism Iran sponsored would not be directed at the US as the US would have removed itself from the Middle East, although that seems extremely realpolitik given Iran's recent history with its neighbors.
Importantly, why else were all sanctions removed from Qassem Soleimani?
The Iran deal’s Qassem Soleimani problem
Buried on page 95 of the draft of the nuclear agreement released by the Russians is the fact that sanctions will be lifted on Qassem Soleimani, head of the Qods Force, the elite unit of the Islamic Revolutionary Guard Corps charged with export of revolution.
Here’s the question: If this was just about Iran’s nuclear program, as President Obama and Secretary of State John Kerry have repeatedly insisted, then why have diplomats agreed to lift sanctions on Soleimani? Then again, perhaps this is a subtle reminder that Soleimani had all along a very deep interest in Iran’s nuclear capabilities after all.
Obama Strikes a Deal--With Qassem Suleimani
... The president seemed to marvel at the fact that from Hezbollah to the Houthis to the Iraqi militias, Iran has such a deep bench of effective proxies willing to advance its interests. Where, he asked, are their equivalent on the Sunni side?
Guess who ran those proxies?
Yes, Qassem Soleimani. He was the key to the way the JCPOA seemingly ceded power in the Middle East to Iran.
And Iran was never in compliance with the JCPOA even pre-Trump:
UN reports increasing violations of Iran nuclear deal
Uranium particles of man-made origin have been discovered at a site in Iran not declared to the United Nations, the U.N. atomic watchdog agency said Monday as it confirmed a litany of violations by Tehran of the 2015 nuclear deal.
The International Atomic Energy Agency said Iran has begun enriching uranium at a heavily fortified installation inside a mountain, is increasing its stockpile of processed uranium, and is exceeding the allowable enrichment levels.
All such steps are prohibited under the agreement Iran reached with world powers to prevent it from building a bomb.
Again, the Obama administration knew all that.
If the goal of the JCPOA were to stop Iranian nuclear research, why continue to support it when Iranian violations came to light?
Again, the only reason logically consistent with that was written about quite a bit contemporaneously with the JCPOA being signed: the actual purpose of the JCPOA was to allow the US to remove itself from the Middle East without creating an entire region of failed states.
And that didn't require actual compliance verification.