Our client suffered a total fire loss to his business, insured on commercial property form CP 00 10 04 02. The debris from the destroyed building has fallen into the foundation and is heaped above ground level. The insurer states that it is not responsible for removing the debris from within the foundation walls; its only responsibility is to pay for removal of debris above ground level, and fill any remaining hole with dirt so as to level the surface. The adjuster cites exclusion 2.f. property not covered: "Covered property does not include… the cost of excavations, grading, backfilling or filling."

Does this exclusion preclude coverage for this debris removal?