Exclusions—Typographic Arrangement Important in Interpreting Policy Language

Please help us to resolve a matter of interpretation of homeowners form HO 00 03 04 91, 4-91 edition. Coverages A (dwelling) and B (other structures) are subject to a three-part set of exclusions labeled with paragraph numbers 1, 2, and 3. At the very end of the exclusions listed under 2, there is a statement about water damage from a plumbing, heating, air conditioning, or sprinkler system, or household appliance. “If any of these” (foregoing exclusions) cause such water damage and it is not itself otherwise excluded, then this contract covers the loss caused by the water along with the cost of opening the building to make the needed repairs. Our question concerns the quoted phrase.

The “If any of these” paragraph is indented under subparagraph e. of 2. Subparagraph e. deals with wear and tear, inherent vice, smog, pollutants, birds, pets, and so on. Some at our company are of the opinion that the intended reference of “these” is to the complete list of exclusions under 2., i.e., (a) freezing of plumbing (b) structural damage to pools, foundations, piers, etc.,  freezing, thawing, pressure or weight of ice or water (c) theft from a dwelling under construction (d) vandalism after 30 consecutive days of vacancy and (e) wear, tear, etc.