Hi Tom -
From what I've seen, you need to comply with the requirements as stated, which means that you will need 10 feet of entryway systems at all entrances. You likely know this, but you can use a combination of entryway systems inside and outside each door to meet the 10 foot requirement.
However, you do raise an excellent question as to the requirements for residential projects, as this is not well addressed in the Reference Guide for many of the LEED-EB: O&M credits, though there are relevant CIRs for some credits. It seems to me that submitting a CIR is your best path. Otherwise, it may be that this credit just might not be appropriate for your particular project type.