[brief] [...]’s motion also makes a half-hearted argument that arbitration is required because of a very narrow arbitration clause in the [...] Umbrella Policy.  Db.19-20.  Endorsement 14 to the Umbrella Policy contains a mandatory arbitration clause requiring that disputes regarding the scope of the pollution exclusion “shall” be arbitrated:  In the event of a disagreement as to the interpretation of Exclusion Q of this policy or a disagreement as to the interpretation [sic] any endorsements attached to this policy amending Exclusion Q, the disagreement shall be submitted to binding arbitration before a panel of three (3) arbitrators.  Da383.  This Umbrella Policy arbitration clause, however, is limited to disputes concerning the meaning of Exclusion Q.  Exclusion Q, which is titled “Pollution”, excludes pollution from coverage under the Umbrella Policy, and defines pollution for purposes of the exclusion.  Da381.  However, [...] has not disputed that Umbrella Policy excludes pollution damages as defined therein, so this mandatory arbitration provision is not applicable here.  While [...] argues that the “best proof” of this dispute is that [...] has not withdrawn the entire Umbrella Policy claim (Db19), a claim generally under the Policy does not necessarily trigger this mandatory arbitration provision.  Instead, the dispute must relate specifically to the far narrower issue of the interpretation of Exclusion Q.  [...]’s brief fails to identify a single pending specific dispute between [...] and [...] concerning the definition of pollution under Exclusion Q that would trigger that mandatory arbitration clause in the Umbrella Policy.  Indeed, [...] concedes that the settlements in the case to date between [...] and various other insurers all had pollution exclusions as well.  Second, even if the claims here related to the narrow mandatory arbitration provision in Exclusion Q of the Umbrella Policy concerning the scope of [...]’s pollution exclusion, waiver still applies to such mandatory arbitration clauses.  See, e.g., Cole, 215 N.J. at 281-83 (applying test to find waiver of mandatory contractual right to arbitration).  [...] failed to raise the Umbrella Policy’s arbitration clause in its Answer or affirmative defenses, signed a contradictory Rule 4:5-1 certification that no arbitration was contemplated under the Umbrella Policy, failed to move to compel arbitration for six years, and actively litigated this policy by filing an opposition to [...]’s cross-motion for partial summary judgment relating to the Umbrella Policy on October 2, 2020.  See Part I.A, supra.  Therefore, as with the Policy, [...] similarly waived any arbitration rights it had under the Umbrella Policy as well.  Third, [...] concedes that other carrier defendants have settled the non-pollution claims with [...].  Db19-20.  Accordingly, [...] cannot now claim – six years later – that it was futile to raise arbitration of any indemnity claim under the Umbrella Policy until now.  Indeed, [...] has argued that the case has primarily concerned the indemnity claims with the other insurers, including at one umbrella insurer, that also had pollution exclusions – which have now been settled with [...].  Db19.  [...]’s Umbrella Policy is unlikely to ever be triggered because of its high attachment point in the insurance tower.  So [...] cannot reasonably argue that it had the only pollution-exclusion policy that could not proceed with arbitration until now.  Accordingly, the narrow Umbrella Policy provision does not require arbitration of this claim and, in any event, has been waived through [...]’s own conduct – and lack thereof.