Light in open 3 story mezzanines

I will agree that the upper spaces do not fall under the specific definition of borrowed light but I can see why the reviewer may have used this language. The prescriptive method is meant for simple geometries and daylighting scenarios because it is all based on formulas. Your situation is not one that would be considered simple. I think the reviewer should have provided a specific reason for saying why they cannot be included or given you a possible method to demonstrate how. Your situation is one that would require more than a narrative to show compliance with the option 2. From a professional side, these spaces cannot technically be included in the prescriptive calculations. You would have to show how much of the 3 story curtain wall glass is allotted to each level. You would then need to establish the depth of the daylighting zone from each allotted area of glass. From the sounds of each, with each level being at 20 feet from the glazing , they might be too far away to have any sizable daylight zone. You cannot use all three floors of glazing for each level, that might actually have too much daylight. What I just described, I have never seen done or attempted with option 2. As you can see, it is complicated and does fit into the simplicity method that option 2 is meant for. You could try it and make a case and see what happens or, do a project team inquiry and ask specifically why the spaces are rejected and what must you show to demonstrate compliance. Personally, I would have done simulations or at least do measurements. The prescriptive is too simple for the scenario you have. Please follow up if you decide to do an inquiry and what the reviewer asks for or whatever path you choose. Good Luck.