Technically, ADA2010 requires you to comply with ADA restroom requirements only to the point where your TI or remodel consumes 20% of your overall cost. Minimum ADA2010 bathrooms are also 7'6x7'6 for 56 sqft... Your architect/design build firm should have made this clear to you. If not, there are professionals. http://www.ada.gov/infoline.htm I once talked to one of the people who drafted the original ADA back in 1988. It was left vague and unclear with the hope that litigation would elaborate and clarify the code for everyone. In other words, they did a shit job of explaining it so that everyone would sue the people trying to comply thereby establishing through caselaw and precedent what they actually meant. As you might imagine, this did not popularize the ADA with merchants, architects, or anyone without a handicapped permit.