Looking for Ontario Code interpretation of window/glazing requirements in basement unit

Hello,

I'm preparing my building basement apartment floorplan and am aware of an Ontario code requirement that the glass area required (total square area of windows) in my open concept kitchen/living/dining must be 18 sq ft.

As part of the plan there is an external entrance leading into this open concept kitchen/living/dining space. As part of the external entrance, I want to use a window that will shine light into the exterior entrance, and therefore into the kitchen/living/dining area. The local building office says that since the window's not on the same story, it wouldn't count towards the total glass area I need. Since I'd be using a large window, and the light would shine through the entire entranceway, it seems to me I could surpass the minimum requirement with this configuration. As for the argument that it's not on the same story, there would be a bit of overlap with the basement story if I kept the window on the exterior entrance low enough to the ground.

My question is: can anyone point me to a section of the Code that would help me prove to the building office that sufficient light is being let into the area by my configuration? I've attached a rough sketchup model of what the configuration would look like.

Thank you.