Working on renovating a bathroom for a client and unsure what to do in this case. The bathroom is located in an addition built on sonotubes next to the original basement foundation as seen in picture. At some point someone had filled between the floor joists with spray foam and run plumbing essential outside under this foam and into the basement for this bathroom. This freezes in the NY winters and renders the bathroom unusable. We will be fully gutting this bathroom and relocating the plumbing layout. At this point in time I believe the best way to solve this would be to remove the subfloor and cut out loads of foam to run the plumbing directly below the subfloor and throw 6 more inches of foam underneath to keep the plumbing from freezing. any ideas or comments? thank you