With the initial Iran Deal done, we are now looking forward to its implementation and verification. That means that the International Atomic Energy Agency (IAEA) will have more work to do over the next six months. But what, exactly, will it be doing?
Most of the IAEA activities called for by the Joint Plan of Action appear to be fully consistent with things the IAEA is doing now, including in Iran. IAEA monitoring of centrifuge production will break new ground and may require an approach that will not offend other uranium-enriching countries. It isn’t clear why the agreement includes the provision for daily inspections at Iran’s enrichment plants. In any case, it would appear that the IAEA has the authority to move forward in doing the needed verification under the agreement.
The Joint Commission
The Preamble of the Joint Plan of Action sets forth that “the IAEA [will be] responsible for verification of nuclear-related measures” called for by Iran and the powers. The deal establishes a Joint Commission that will consist of representatives from the powers and Iran to “monitor the implementation of… near-term measures. The Joint Commission will work with the IAEA to facilitate resolution of past and present issues of concern.”
What will be the specific tasks of the Joint Commission? Some participants in discussions with the IAEA claim to know that the Joint Commission’s members will concern themselves primarily with sanctions-related issues, leaving nuclear verification to the IAEA, regardless of whatever may be implied by the above reference to a cooperative relationship between the Joint Commission and the Vienna agency, which is not spelled out in the text. The IAEA is not a party to the Iran Deal, and it is not a member of the Joint Commission. If media reports are correct, however, the IAEA will attend an initial meeting of the Joint Commission early next week. By then at the latest, the IAEA, Iran, and the powers must know what is in store for the IAEA in dealing with the Joint Commission. If it is intended that the Joint Commission wikk work closely with the IAEA, there must be an understanding to protect confidentiality of information. Beyond that, any Joint Commission participation in any IAEA verification activities in Iran would pose serious legal and confidentiality issues.
Enhanced Monitoring
The text of the Joint Plan of Action says this about the IAEA’s role under the rubric “enhanced monitoring”:
Iran would undertake the following voluntary measures:
- Provision of specified information to the IAEA, including information on Iran’s plans for nuclear facilities, a description of each building on each nuclear site, a description of the scale of operations for each location engaged in specific nuclear activities, information on uranium mines and mills, and information on source material. This information would be provided within three months of the adoption of these measures.
- Submission of an updated DIQ [Design Information Questionnaire] for the reactor at Arak, designated by the IAEA as the IR-40, to the IAEA.
- Steps to agree with the IAEA on conclusion of the Safeguards Approach for the reactor at Arak, designated by the IAEA as the IR-40.
- Daily IAEA inspector access when inspectors are not present for the purpose of Design Information Verification, Interim Inventory Verification, Physical Inventory Verification, and unannounced inspections, for the purpose of access to offline surveillance records, at Fordow and Natanz.
- IAEA inspector managed access to: centrifuge assembly workshops; centrifuge rotor production workshops and storage facilities; and uranium mines and mills.
The first and the last of the above points appear to follow from the Framework for Cooperation, which Iran and the IAEA signed in Tehran on November 11. The Annex to that agreement specifically mentions only two locations: the Gchine mine and the heavy water production plant located adjacent to the IR-40 reactor under construction. The IAEA will visit the heavy water production plant on Sunday. But that visit is unrelated to the steps called for in the Joint Plan of Action.
It is understood that the IAEA will need more resources–personnel and money–to do the verification work called for under the Joint Plan of Action. But the amounts need not be very great, since most of the work the IAEA will be asked to do follows from its application of routine safeguards at declared installations in Iran. Much of the scope of work itself would appear to be well within the IAEA’s existing competencies and routine activities, including in Iran:
- At Iran’s Pilot Fuel Enrichment Plant (PFEP) at Natanz and the Fordo Fuel Enrichment Plant (FFEP) enrichment plants, the IAEA could without difficulty, using its existing inspection regime with some extra inspection activities, verify that Iran has halted all enrichment above 5% and dismantled the connections necessary to enrich to above 5% U-235.
- The IAEA could verify the downblending of Iran’s inventory of 20%-enriched uranium at PFEP and maybe also at FFEP. At the Fuel Enrichment Plant (FEP) at Natanz it would verifiy that the UF6 is converted to oxide. Additional inspections may be required to meet the six-month timetable.
- With some extra inspection activity, the IAEA could without difficulty verify that no additional centrifuges are being installed and that designated installed centrifuge capacity at both enrichment plants is idle.
- The IAEA can verify that the IR-40 is not operating, and that Iran is not making or testing fuel, or installing equipment at the reactor. The IAEA can carry out inspections for this purpose at the Arak site, at the Tehran Research Reactor (TRR), and at a critical facility.
- The IAEA can confirm that it has no information that Iran is not violating its agreement not to build a reprocessing plant for the IR-40. This issue should not be a problem under the agreement. If Iran were to inform the IAEA it is constructing a hot cell facility, the IAEA would in any case have to inspect it quickly to verify design information.
- The same applies for construction of any new uranium enrichment facilities in Iran.
- It should be possible for the IAEA to obtain information about Iran’s mining and milling activities, as well as about heavy water production, during the next six months.
- Ditto for long-sought design information verification (DIV), more frequent inspector access, and provision of key data, consistent with the modified Code 3.1 and the Additional Protocol, for the IR-40 reactor.
Problem Areas
A few activities that the Joint Plan of Action calls upon the IAEA to perform do raise some potential issues.
The inventory of uranium enriched to 3.5% U-235: Iran has committed to halt progress in the growth of this stockpile. Iran must not increase the inventory such that the amount at the end of six months is not greater than at the beginning, and Iran must convert any newly-enriched uranium from UF6 to oxide. The IAEA can verify this at the FEP/PFEP and FFEP using its established inspection regime. But the six-month timeline may mean that the IAEA should perform an interim physical inventory verification (PIV) at these installations near the end of the six-month period.
Verifying Iran’s compliance on centrifuge production: This action is new and requires additional resources and agreement with Iran and the powers over what it entails. The IAEA is not doing this in other countries with centrifuge enrichment programs. It is possible that enriching states–the members of the Almelo Treaty, France, Russia, China, Brazil, Japan, perhaps even the U.S.–would not want to see the IAEA expand its authority into centrifuge production monitoring, in part for nonproliferation and intellectual property reasons. A “black box” approach to this challenge in Iran may therefore be the answer.
Daily inspections at Natanz and Fordo: Iran has committed to provide inspectors daily access at these facilities to ensure comprehensive monitoring. It isn’t clear why. Does the IAEA want to use this provision to increase the frequency of its inspections? If so, then the agency will have to work out the logistics required.
IAEA safeguards aficionados will tell you that, in safeguards terminology, “daily presence” means “continuous inspection”–a notion which was introduced for use at reprocessing plants, where significant quantities of material are constantly flowing. There’s lots of material flowing at enrichment plants, too, but the amounts are by comparison small; the IAEA only needs to look at the feed, product, and tails to do a material balance at the plant. The enriched uranium product is collected in cylinders that fill up slowly and are detached from the process when full. What is of safeguards significance is how much and what material is in the product cylinders and where are they stored. (There is also the issue of undeclared feed and take-off points to reckon with.) So the question is whether the IAEA really needs “continuous inspection” to ensure against undeclared movement of product cylinders. The IAEA doesn’t really need 24/7 personnel presence in at least some enrichment plants operating today. Having inspectors in the plant all the time might make the window of opportunity for a diversion smaller, but the marginal value may be very limited.
The IAEA’s response to this point in the Joint Plan of Action may depend on the specific design of the enrichment plants in Iran. At Russian centrifuge plants, some settings which would be diversion-critical are made in the control room and the change would take just 15 minutes to accomplish. At Urenco plants, the same operations would require making hardware adjustments in the piping in centrifuge cascades.
IAEA Resources
Right now, the IAEA is spending a lot of money on safeguards in Iran–US $12,256,000 in 2012. That’s more than for any other IAEA member state except Japan. The lion’s share of this amount pays for activities related to the IAEA’s investigation of Iran’s nuclear program under mandates from the IAEA board of governors and the U.N. Security Council–not routine inspections at declared facilities. Routine safeguards are comparatively inexpensive. Like Iran, the Netherlands has a large uranium enrichment plant and one power reactor. Routine safeguarding of nuclear activities in the Netherlands, however, last year cost only $1,888,000.
At any one time, the IAEA probably has no more than about four or five personnel on the ground in Iran doing safeguards. A few more–certainly not 100 or even a score–may be needed to fulfil the IAEA’s expanded mission under the Joint Plan of Action.
The same goes for the money that will be needed. This will likely be a small fraction of the total current safeguards cost in Iran. Since the IAEA passed its 2014 budget at the General Conference three months ago, the easiest solution would be for member states–most logically the six powers themselves–to agree to pay the costs under an extrabudgetary program. In the past some states have objected to the growth of extrabudgetary funding to cover the costs of IAEA safeguards. But it is not anticipated that this concern will stand in the way of funding verification under the Joint Plan of Action because most states on the IAEA board–on the basis of statements they made during the board meeting last week–clearly support the results of Iran’s diplomacy with the six.
The IAEA’s Authority
Does the IAEA have the authority to do the work? Right after the Iran deal was closed in Geneva, questions in Vienna arose about that because, as I have said above, the IAEA is not a party to this agreement. The agreement itself is based on voluntary commitments by Iran and the six powers–not legal obligations.
As of last week’s board meeting, it wasn’t clear how the IAEA would proceed. Director General Yukiya Amano had proposed internally convening an extraordinary board meeting pertaining to the IAEA’s response to the Joint Plan of Action. Less clear last week was whether the IAEA would inform the board of its intentions or instead seek its formal approval.
In any case, it would appear that the agency has the authority go do the work which Iran and the powers assign to it under the agreement, as Article III A. 5 of the IAEA Statute tells us:
The Agency is authorized… to establish and administer safeguards designed to ensure that special fissionable and other materials, services, equipment, facilities, and information made available by the Agency or at its request or under its supervision or control are not used in such a way as to further any military purpose; and to apply safeguards, at the request of the parties, to any bilateral or multilateral arrangement, or at the request of a State, to any of that State’s activities in the field of atomic energy.
PMD Reporting
The Joint Plan of Action says that the IAEA and the Joint Commission are to cooperate to “facilitate resolution of past and present issues of concern” but it does not make specific reference to “Possible Military Dimensions” in Iran’s nuclear program, which has been the subject of IAEA formal reporting to the board of governors since November 2011. The IAEA-Iran Framework for Cooperation likewise states that Iran will “resolve all present and past issues.”
Iran has not provided the IAEA answers to any key PMD-related questions since 2009. It is unlikely that all of these questions will be answered during the next six months. How much information the Iran gives to the IAEA will no doubt be subject to negotiation during this period along the lines of what the IAEA and Iran agreed upon on November 11 in Tehran. At the end of a year, assuming that six months will not suffice to reach a comprehensive settlement of the Iran conundrum, perhaps the biggest challenge will then appear: If we assume that Iran implements all other conditions of the Joint Plan of Action, save divulging what may be compromising details about its previous nuclear activities, how much about Iran’s most sensitive nuclear past must the IAEA know for the six powers to make a deal with Iran looking into the future?
Mark, I agree that the IAEA can oversee the parts of the Joint Plan relating to centrifuges, but I don’t see anything in the Joint Plan about dismantling connections that allow enrichment to 20%. The Plan says that Iran will not enrich above 5%, but the centrifuges now enriching to 20% could just be idled. If they were to be used to enrich to 5%, then the connections would have to be changed.
Cheryl,
Board member country representatives from countries that should know this, in the VIC last week, claimed to know that the footnote in the Joint Plan of Action concerning this issue: “No interconnections between cascades” means that these cascade connections will be disconnected and new ones not permitted, thereby limiting the enrichment level. Some others were less categorical about this detail. In any event, should Iran be required to physically disconnect the cascades, that could be verified by the IAEA.
The problem with the PMDs is not Iran but the IAEA. Iran agreed as part of the Modalities Agreement to provide their analysis of the claims to the IAEA upon receipt of the documentation — and the documentation has not been provided to Iran (or, in many cases, to the IAEA) and yet Iran is expected to refute allegations it cannot see. But Iran did file a 117 page analysis which showed that the allegations are false or even nonsense (why would Iran hide its Green Salt production when it quite proudly announced it in the media?)
Indeed most of what the IAEA is charged with verifying in this deal is already part of Iran’s standard safeguards obligations. It should however be pointed out that this is only an interim agreement, which provides that eventually all of the extra-legalmeasures will cease and Iran’s nuclear file will return to same status as any other NPT signatory. Furthermore, these concessions by Iran are in fact less than what Iran had offered before, but which the US refused to acknowledge.
Mark, I agree with you on daily inspections of centrifuges, etc. My reckless surmise based on what I used to know about safeguards is that some folks decided daily inspector access sounded like a good thing, a salable, easy-to-understand public relations point, so it went in the Framework essentially for political reasons. “Daily inspections” sounds better than “surprise” or, God-forbid, “randomized” inspections of the most prominent facilities of concern. Maybe the fine hand of the White House is in the background somewhere. I can think of no other reason, with my limited technical knowledge, why daily visits would add substance to any conclusions the inspectorate could reach on their own.
However, it will cost more money, so Nackaerts and Co. may have a few more bucks, which is always to the good.
I guess I mean Varjoranta, and I guess I need to visit the IAEA site more often.
For some reason the cameras are not monitored in real time, i.e. there is no electronic network connection from the monitoring cameras to an offsite IAEA monitoring station. The cameras apparently record some kind of video that must be daily collected an analyzed to make sure that Iran has not engaged in some kind of re-plumping/moving of UF6 cylinders to other cascades sprint to weapons grade enrichment.
Clearly the intent of near-real time monitoring as opposed to monthly inspections is to 1) make sure that some surreptitious enrichment reconfiguration is not happening when the inspectors are off site; and 2) provide a much shorter mean time to detection of an enrichment violation.
I am not sure how often the enrichment facilities are inspected now. We seem to get a IAEA report every three months. If the actual current inspections/film dump/analysis is once per month, the daily inspections take one month off of sprint detection. As has been shown elsewhere, with sufficient 20% UF6 feedstock (a few hundred kilograms), and with a more efficient set of IR-2m cascades (say 1000 centrifuges), breakout enrichment to weapons grade could occur within this one month time frame.
Anyone else — am I missing something?
Typo Corrections:
“collected and analyzed”, not “collected an analyzed”
“re-plumbing”, not “re-plumping”
I liked re-plumping.
IMHO, the world should get used to real time monitoring of all enrichment plants. One designed to fuel 2 nuclear power plants has the SWUs for 50 or so weapons per year.
Here is a connundrum: In the case of enrichment plants, if you detect breakout in time you can prevent any weapons-usable material from being created, through aerial bombardment. But if a country breaks out along the Pu route, and already has 5 years of spent fuel in its cooling ponds – it seems like there is nothing anyone can do stop them from making weapons. We weren’t even willing to bomb the small amount of Pu in N. Korea when they kicked out the inspectors.
Any useful ideas on this?
Yes, my idea was to have new “NPT 2.0”:
http://www.foreignpolicy.com/articles/2012/12/18/radioactive_decay?page=full
Yousef,
Thanks for responding to my question. I enjoyed your article about NPT 2.0. I think I agree with nearly everything you said, with the possible exception of the slightly disparaging remarks about the “Beatles era.” I am worried, as are many, about trying to get nearly 200 states to sign a new treaty. Think of how the U.S Senate would demand to be bribed.
I am also concerned that a treaty that bans reprocessing does not help much in the breakout scenario I discussed in my post. If you have 500 kg of Pu in your cooling ponds on the day you kick out the inspectors… It seems to me that you can do whatever you like with it, unless someone is willing to bomb your cooling ponds or invade you.
Yousef,
Along the lines of your NPT 2.0, it seems to me that the U.S. should be offering Iran, which is floating on natural gas, modern combined-cycle gas turbines for electricity production.
I am all for the gas turbines.
I am familiar with the “we should keep a shitty treaty that no-one believes in or respects because it got a lot of signatures”, but the problem is that such an attitude inhibits thought.
Yousaf,
What about my coming-in issue of the difference between breakout with uranium enrichment plants (no fissile material available at breakout) and with spent fuel (plenty of fissile material available at breakout)?
– Rob
Rob, I think some serious consideration would be needed on the subject of how reactor-grade Pu produced from high burn-up is made weapons-useable. It seems to me that safeguards could verify high burn-up.
Mark, the disconnection of interconnections creating the “tandem cascades” will not block alone the use of a cascade to produce 20 % enriched uranium from 3-5 % UF6 feed. Tandem cascades were designed by the Iranian engineers to improve the efficiency of the enrichment process. The original AQK four step process did not have such interconnections.
Mark, the safeguards approach for the Iranian enrichment plants is close to a “Black Box” principle, where the IAEA monitors with cameras, load cells and seals feeding UF6 to cascades and withdrawal of enriched uranium and tails from the process. Additional cameras control the perimeters of cascades halls to ensure that no material is removed directly from cascades. Thus the cameras do not see centrifuges and piping in cascade halls. The purpose of the unannounced inspections, which access the cascades areas, is to ensure that there are no changes to the piping to produce higher enrichments, or additional feed and withdrawal stations on those areas. These measures cover also the use of the facility for excess production of declared types of materials. In addition the IAEA takes environmental samples and strikes monthly balances of nuclear material to confirm the statements of the operator.
The Joint Plan of Action talks about the IAEA daily access to the surveillance records. In order to improve the timeliness of detection, the IAEA should, at this stage, negotiate also more frequent access to cascade areas, and other relevant areas in Natanz and Fordow. In addition the IAEA should seal the stocks of enriched UF6 and uranium oxides in Natanz, Fordow, and Isfahan, and, importantly, have more frequent access to those materials.
Mark, with regard to the monitoring of the production of centrifuge rotors, the IAEA did in Iran pursuant to the 2003 suspension agreement between EU3 and Iran monitoring of non-production of centrifuges, which went beyond the monitoring requirements of this Joint Plan. In order to set the baseline for the monitoring, the IAEA estimated that time the cumulative number of rotors produced in Iran or imported from elsewhere using, inter alia, information on the consumption and stocks of key raw materials such as maraging steel or high strength aluminum. You will find details on that scheme, which was negotiated between the IAEA and Iran, in the report to the IAEA March 2004 Board. Similar work was also done in 2004/5 for centrifuges acquired or under manufacturing in and for Libya. I am sure that the IAEA will in coming weeks negotiate similar arrangements for the Joint Plan to establish the stocks of manufactured centrifuge rotors, and to monitor the production of the replacements.
I would be interested in the mechanism whereby the P5+1 assigned IAEA duties in Iran. e.g. Did the IAEA a priori grant the P5+1 carte blanche in designating the IAEA whatever duties they saw fit or was there some consultation between the IAEA and P5+1 during the negotiations? Does the IAEA have a say in implementing the duties assigned to it by the P5+1 ?
Yousaf,
Call ++43-1-2600-0.
Ask the operator to speak to Mr. Graham Andrew in the Director General’s office. He will certainly be able to answer your questions in sufficient detail.
Can you identify yourself as representing an IAEA member state government in this matter? If so there is a chance that Mr Andrew will come to the phone.
During the run-up to the Iran Deal conclusion, an extremely small number of IAEA staff were occasionally briefed by the U.S. and perhaps other P5+1 governments about the ongoing negotiations with Iran prior to November 22. Non P5+1 IAEA member states were not officially briefed in Vienna so you won’t get any reliable information from those quarters.
In the case that you qualify as I describe above and you get connected, please ask these important questions.
Otherwise, I am highly confident that what I wrote in the blog post is correct.
Thanks Mark. I’ll try to call them collect — will let you know result.
BTW, what do you think — will Brazil and Japan abide by the rules hashed out for Iran?
http://thebulletin.org/iran-interim-agreement-international-precedent-nuclear-rules
Cute logic there. Maybe IAEA will need huge injection of funds from NPEC?
Olli and Mark,
Can somebody explain this odd language?–
“Daily IAEA inspector access when inspectors are not present for the purpose of Design Information Verification, Interim Inventory Verification, Physical
Inventory Verification, and unannounced inspections, for the purpose of access to offline surveillance records, at Fordow and Natanz.”
There does not appear to be a daily and unannounced inspection under these terms and where there is, it is constrained.
I interpret this to mean that a “daily access” cannot happen during a DIV, PIV nor and IIV; and that “unannounced inspections” may only take place for the purpose of verifying recorded operating data at Natanz and Fordow. These appear to qualify/constrain what both daily and unannounced accesses can do, when they are used.
Thus, a daily inspection might be related to a DIV or a PIV but is not for a DIV or a PIV? Are there examples of this from normal inspection activity?
Tom, the text, indeed, describes in a complicated way a simple thing, which is to provide a daily inspector access to Fordow and Natanz through the year (or in this case for 6 months). But this additional access appears to be only limited for retrieving and reviewing the surveillance data, which means, for example, that the cascade areas are not visited or nuclear material is verified. Visits to cascade areas take place during unannounced inspections, which are done on average once or twice a month. The IIVs are once a month, and inspectors spend perhaps two to three days to do that. A PIV is once a year, and lasts perhaps three days. DIV is not an inspection, but a visit to confirm changes done to the facilities, which both are operating, but still also under construction. These visits likely include access to cascade areas, but, since they are not inspections, no verification of nuclear material or surveillance record review is included to those activities. If the scope of these new “daily” visits are the way I read them, it might be good to have them, but they are of a limited additional value. I am sure that the IAEA will review now its activities in their totality at all facilities in Isfahan, Natanz, and Fordow, and makes revisions as I have described above.
The most important part of this interim agreement is what *isn’t* in it i.e. the complete absence of the phrase “Possible Military Dimensions”, replaced by the much more airy-fairy “past and present issues of concern”.
I suspect that the significance is this: at the end of the six months (well, 12 months because they will invoke the extension) then the P5+1 will simply handwave away then PMD allegations with a quick “awwwww, that doesn’t concern us any more”.
And, really, why should it?
Consider this possibility: Iran keeps its nose clean during this interim period, at the end of which the P5+1 negotiates a final deal that satisfies their requirement for “correctness and completeness”.
If they get that then why would they want to spoil it all by harping on about stuff that Iran did (or didn’t) do More Than A Decade Ago, once they become satisfied that Iran Ain’t Doing It No More?
Better to regard that as water under the bridge, sleeping dogs, put it all behind us, fresh start, etc. etc…..
Yeah. And that stuff about “past and present issues of concern” is in the paragraph of the Preamble that starts out discussing “steps in between”. It will be tricky to fit steps in between a renewable six-month “first step” and a “final step” that is to start in one year. Of course this could be part of the “final step”, even though it is not on the list of its elements.
I would guess that the Iranians did not want PMD mentioned explicitly, and the West figured that the ambiguity was good enough for them. Or maybe they even thought it would be helpful to have the bargaining chip of the option to shame Iran, or not shame Iran, for violating the Supreme Leader’s Fatwa. They lose the optional feature if PMD is explicit.
Perhaps because the phrase always was *possible* military dimensions, and perhaps because Iran allowed access to Parchin twice, and perhaps because Iran hs never been confronted with the full evidence of what it is accused of, it is indeed smart of the P5+1 and the IAEA to let this *possible* stuff from a decade or so ago slip. You know, like the Swiss nuclear weapons program.
For more detailed reasons of why the PMD issue should not inhibit a deal see:
http://armscontrollaw.com/2013/01/22/yousaf-butt-pretty-in-pink-the-parchin-preoccupation-paradox/
For Bob Kelley’s view, see:
http://therealnews.com/t2/index.php?option=com_content&task=view&id=31&Itemid=74&jumival=11080
I respectfully disagree with your assessment of the posture of the West. Immediately after signing the Joint Plan, the U.S. made a statement to the IAEA board of governors, which includes this line: “We … hope that the November 11 ‘Joint Statement on a Framework for Cooperation’ will be a vehicle for resolving all present and past issues – including those related to PMD – without further delay. … We will continue to gauge closely Iran’s willingness to address the international community’s concerns, including whether issues directly related to PMD are addressed in the next phase of agreed upon measures.”
http://vienna.usmission.gov/131128iran.html
So it seems like the US is already promoting an expansive interpretation of “present and past issues” that includes PMD.
Oh, sure, Rene, the USA is going to spin this hard by declaring that as far as they are concerned those two phrases mean the same thing.
But, honestly, if wishes were horses then we’d all be Kings.
The Joint Statement does represent a walking back (otherwise “PMD” would be in there, and it isn’t), and I would suggest that having started this backpedalling that the USA will continue to MoonWalk its way out of this corner.
Or, put another way: if allegations of PMD (which, remember, all date back to pre-2003) ends up standing in the way of a final agreement then the choice will be:
a) Throw those allegations away, or
b) Ditch that final agreement.
I know which one I’d chose if I were Leader Of The Free World.
One thing that’s interesting about this plan is that it coudl be considered a testbed for approaches to verification of the FMCT.