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MN 1311,Section 301.1 makes provisions for three unique compliance paths. Adherence to any one of these three compliance paths satisfies the requirements of the code. 1311.301.1 "Prescriptive Methods" states that repairs, alterations or changes of occupancy complying with Chapter 4 of this(MN 1311) cbde shall be considered in compliance with the provisions of this code. Plumbing and fixture counts for plumbing are NOT ADDRESSED in Chapter 4, even when related to change of occupancy. Accessibility refers to the 2015 Minnesota Accessibility Code. 1311.301.2 "Work Area Compliance Method" includes Chapters 5 through 13 of 1311. Chapter 10 deals with change in occupancy, but the plumbing fixtures are only addressed when there is an increase or difference in plumbing fixture requirements (Section 1010.1). The proposed project has a decrease in demand. It is gray if the difference (decrease) in fixture count requirements could/should drive an increase in work scope, since a zero change in fixture count requirements would not trigger the change. But, if a change requirement is interpreted,then 1311.1010.1 refers to 4715 which refers back to 1305 in 4715.12.10. Convoluted but true. -similarly,Section 810.1 states that where there is an increase in plumbing fixture demand by more than 20%,then the plumbing fixtures shall be provided in accordance with 1305. Code is silent on reduction of loading. -Section 1012.1.4 states that all buildings undergoing a change of occupancy classification shall comply with Section 1012.8, which refers to the Minnesota Accessibility Code. 1311.301.3 "Performance Comqliance Method" refers to 1311, chapter 14. Section 1401.2.4 has the language that code officials want to see..." can't alter the building to be less safe or less sanitary than the current building. If the current level of safety or sanitation is reduced, it may not be reduced to that below Chapters 2-12 and 14-33 of the IBC. Note that we never get here unless the designer opts for the Performance Compliance Method. Bottom Line: Since the occupant load for the mercantile space is greater than 100,separate facilities are still required for men and women. Since separate facilities exist,they need to continue to be provided,or they need to be replaced with new meeting the current requirements. Accessibility Code 1341,section 1112.8.3 requires that if the existing restrooms remain,they must be upgraded to provide wheelchair accessible stalls in both the men's and the women's restrooms. If this is technically infeasible,then a separate accessible unisex toilet may be added. If the new tenant opts to demolish the existing facilities and provide new,separate accessible toilets will be required for both genders. Greg Metz � Construction Code Rep � Architect MN- DLI Construction Codes& Licensing Division From: Roger Peitso [mailto:rpeitso@ci.orono.mn.us] Sent: Tuesday, July 14, 2015 12:36 PM To: Metz, Greg (DLI) Cc: Jeremy Barnhart Subject: Plan Review G reg, Here is a copy of the plans I was given. The architect didn't sign them and there was quite a few problems with the clearances at the doors so I have a review letter into him. Also this is technically a basement, there is a story above this that empties onto the street level. Any questions please give me a call. Thanks, Roger Peitso Building Official 3