Last week, the New York Times examined how sanctions that prevent Iran from purchasing Western aircraft and spare parts are hurting ordinary Iranians and have contributed to a record of over 1,700 plane crash deaths in Iran over the past decade.
David Cohen, the Treasury Department Under Secretary for Terrorism and Financial Intelligence–who is responsible for enforcing sanctions–disputed the article and defended the aircraft sanctions.  He wrote that Iran Air aids Iranian weapons proliferation and so is not a purely civilian airline.  He also asserted that the U.S. does allow for inspections and repairs of Iranian civilian aircraft as long as the services are performed outside of Iran.
But Cohen’s response leaves out some very important points.
Although his first point is true – Iran Air is not only a passenger airline, but also provides services to Iran’s Ministry of Defense and Armed Forces Logistics, Cohen incorrectly cites June 2011 as the date these sanctions began. In reality, Iran has been unable to purchase Western planes or parts since 1979. Due to decades of sanctions, Iran’s aging fleet of airplanes has one of the worst air safety records in the world, suffering from at least one major plane accident a year. Iranian aircraft safety is so terrible that Iran Air was banned from flying over European airspace in 2010, due to safety concerns.
Cohen’s second point is also technically true: the U.S. has “issued licenses to allow for the inspection, and in previous years also the repair, of Iran’s civilian aircraft, so long as those services were performed outside Iran so the parts and services could not be misdirected to Iran’s military aircraft.”
However, he fails to mention that, if Iran were to send planes outside of the country, it is not unreasonable to suspect that the planes would be tampered with or bugged with espionage equipment. Given the recent barrage of espionage-related activities against Iran – ranging from assassinations to computer viruses – it is no surprise that Tehran would be unwilling to allow Iranian airplanes to be inspected or repaired under U.S. auspices in a third country. Thus, Iran will likely not risk sending any planes outside of the country for inspection.
Most importantly, Cohen’s letter fails to recognize that unilateral American sanctions on Iranian civilian airplanes directly disregard international law.  These laws, as articulated by the UN, forbid severe sanctions that cause a disproportionate amount of damage to a civilian population.  With over 1,700 passengers and crewmembers dead in the last decade alone, it’s hard to argue that these sanctions do not cause disproportionate amounts of damage to the ordinary citizens of Iran.
Additionally, the International Civil Aviation Organization (ICAO), to which the U.S. is a signatory, has said: “United States sanctions against the Islamic Republic of Iran have adversely affected the safety of civil aviation. The findings of ICAO should be upsetting to anyone, who is committed to the safety of civil aviation and the safety of air transport.”
The Iranian government certainly is guilty of draconian repression and abuses against its own citizens, not to mention economic mismanagement and erratic behavior by its rulers on the world stage that fuel antagonism.  But the United States must hold itself to a higher standard.   We should be pursuing humanitarian measures to help ensure that sanctions do not contribute to the deaths of innocent civilians, rather than disregarding international law and instituting indiscriminate sanctions that lead to countless civilian deaths. Sanctions need to be targeted at human rights abusers in Iran, not Iranian civilians who themselves are aspiring for greater political, economic and social freedoms.

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