Providing carpool spaces within an unreserved parking garage

Same situation as above. Not offering a response, but...perhaps my post will bump this question back up and we can get some feedback.

The ref guide says provide 5% preferred parking and then defines preferred parking as "Preferred parking, available to particular users, includes designated spaces close to the building (aside from designated handicapped spots), designated covered spaces, discounted parking passes, and guaranteed passes in a lottery system" as one of a list of items in the definition (notice...all connected with the 'and'). This shouldn't be confused with our longer term understanding of PP for HE/LE vehicles or now Green Vehicles LT credit - which is quite specific about the location.

I'm proceeding with submitting this credit with the position that since the project buys ALL 100% of the passes (discounted) that they are all preferred parking by definition. No other assigned parking exists and any passes other than those managed by the project are at the parkers expense. Not to be reimbursed by the project. Street parking is excluded - and presumably the parkers could hunt down a street spot if they did not wish to park in a garage and pay for it.

I'll be ensuring that the project does not provide more passes than the zone allows and also achieving the required reduction as well. AND has absolutely no assigned parking spaces associated with the project or space.

Landry, have you submitted and received feedback on your approach?
I would think that USGBC would expect a project to provide reserved, preferred spaces if parking is provided, regardless of whether the garage is under the control of the tenant or not. I have seen feedback similar to this in the past. They expect your project to work with the garage owner to designate the number of spots required.
Otherwise, if your project is providing parking, and you cannot designate the preferred spots required, your project would just not be eligible for this credit.

Have not submitted it yet, but will provide feedback when we get it.