We are looking for an opinion on this coverage scenario. We have a sawmill that sustained a fairly significant fire to their mill. The concrete floor of the mill also serves as foundation for the structure and permanently installed machinery. The CP 00 10 10 12 form, has the following exclusion:

•g. Foundations of buildings, structures, machinery or boilers if their foundations are below:
o(1) The lowest basement floor; or
o(2) The surface of the ground, if there is no basement;

We have argued with the carrier to try and cover some of the concrete as building as it serves as the floor of the sawmill and as a foundation for permanently installed machinery (concrete is above the surface of the ground). How do you read the interpretation of the above language? Foundations of buildings are completely excluded or only if the foundations are below 1 or 2 in the exclusion. There is no basement at the mill.

Pennsylvania Subscriber

When a policy term is undefined, we must go to its common meaning as found in a standard desk reference. Merriam Webster defines foundation in part to mean:
4 : an underlying base or support - especially: the whole masonry substructure of a building
5 a:a body or ground upon which something is built up or overlaid

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