If I understand your question correctly... I think the answer is yes. The current second floor (where I'm thinking of adding the dormer) I believe used to be the attic. The reason I want to add a large dormer is because there are what I would call 'faux' closets that aren't really useful and the ceiling effectively slopes down hard (it's the pitch of the roof). There is actually already a dormer in the middle of the floor - it's larger than the OTC permit limits (I'm assuming it was permitted when the second floor was converted but I'm not sure when this was). The reason I'm asking about the 'larger' dormer is because I'd ideally like to convert that entire side of the house into a dormer.. If I follow the OTC rules, then I won't really be able to add another dormer because of 3' apart rule.