I have a commercial client who is the owner of a new-construction, multi-tenant building entering the final review phase of LEED-CS. I have a few questions about potential ID credits:

1. We have already been denied our attempt at LEED-EBOM MRp1, "Sustainable Purchasing Policy" because it was argued that the owner is unable to control the tenants' purchases.
Instead, we would like to pursue LEED-EBOM MRc2.1 "Occupant Comfort, Occupant Survey", but I am concerned: will this also be denied upon the premise that the owner cannot control the how the tenants maintain their space thermally, etc.?
Would it be possible to achieve either of these credits by adding pertinent verbage to the Tenant Manual, and mandating that tenants agree to the Tenant Manual as part of their lease?

2. We are pursuing LEED-EBOM IEQc3.1 "Green Cleaning, High Performance Cleaning Program" as one of our ID credits.
Can we also pursue LEED-EBOM IEQc3.9 "Green Cleaning, Indoor Integrated Pest Management" as another [separate] ID credit, or will it be deined based upon the argument that IEQc3.9 falls under IEQc3.1?