Determining the Owner/Tenant % Controlled for ACP

I have a C&S medical office building that is 88% tenant space (by area) and am trying to figure out how to correctly document the owner/tenant % of the building energy cost for the Core and Shell alternative compliance addendum. The owner is responsible for everything except the tenant lighting and receptacle loads. I am using Trace 700 for this model and, so far, have not found a way to input separate energy meters so my question is twofold: 1. Can I provide a separate calculation to document the energy costs of the tenant receptacle and lighting loads? 2. I am using the building area method for lighting (1W/SF) and Appendix 2 from the 2009 C&S Rating System to determine my minimum receptacle load (1.5 W/SF). However, in order to meet the minimum 25%, the actual modeled receptacle load is closer to 1.8 W/SF. Since both of these numbers are applied to the building as a whole, it is acceptable to apply the ratio of tenant area to total area (88% in this case) to the total receptacle and lighting costs for the year? For example, 88.8% of my yearly receptacle and lighting energy usage is 1156.9 Mbtu or $39,840 at 11.65 cents per kWh. Since my total building utility cost is approximately $66,400 per year, the building is 60% tenant controlled. Would this be an acceptable way to document the owner controlled percentage for the alternate compliance path?