You do know 1104.4 Multistory Buildings and Facilities, does not say you do not need access. It says one accessible route shall connect each accessible story , it does not exempt it from access from the outside.I am in CO, but as I read it, the space is very small and meets the exception for under 3,000ft² and directly below the accessible level.
Colorado Building Code
- 1104.4 Multistory Buildings and Facilities
- At least one accessible route shall connect each accessible story, mezzanine and occupied roofs in multilevel buildings and facilities.