There are only two toilet rooms required based on the requirement for separate facilities. They are proposing 3, two non-accessible and one accessible. They are not clustered. The conundrum is that the two non-accessible are not being altered beyond cosmetics, so they are proposing that since they are not part of the "alteration", that they don't need to comply. New construction would require 2 fully accessible toilet rooms, they are proposing 1, so it is less than the new construction threshold.
IEBC 305.6-specific to accessibility says that a facility must comply with IBC ch. 11. The issue here is "facility", (and a more specific reference to ch. 11 of the IBC). Are we limited the elements of the facility undergoing alteration? Or are we including the entire facility, and increasing the scope of work beyond what is being altered?
IEBC 503.1 clearly indicates that only the "alterations" need to comply with the IBC, but this is a general reference to the entire body of the IBC, not the specific reference to ch. 11 of the IBC. So when the architect references this section as his way out I could say the more specific reference towards accessibility of 305.6 applies.
I would love to believe the differences in the wording of these two codes is intentional, and that they specifically differentiate between facility in 305 and alteration in 503 to provide the answer to this question. But I am not confident in that.
Steveray, where does that code section (306.3.1) you reference come from?
To correct my initial post, I determined that there were some accessibility issues with the 2 that I thought were originally accessible. So, there is no reduction from the current conditions since NONE OF THE SIX TOILET ROOMS WAS ACCESSIBLE. How and why?......because the previous DP, contractor, owner, plans examiner, inspector.....didn't do their job? This is not an excessively old building, and certainly the previous tenant permits are not old enough to excuse this. Alas, the failure of others to do their job does not excuse me from doing mine.
Is it 5 O'clock somewhere yet?