Private Shuttles

Has anyone heard of using the EBOM credit to replace this one showing trip reduction? My project is served by private campus shuttles from Mon-Fri, including 5-10 different bus lines, intercampus shuttles, and shuttles to the nearby public transportation options. This is a secure facility with no visitors so only the office occupants need to utilize these options. We are greatly reducing single-occupancy vehicles and it's frustrating the private shuttle option has been removed, since this company created their own shuttle service to accommodate the occupants that do not have other public transportation options. Might be worth submitting a CIR? Wondering if anyone else has had luck with this. Thanks!