The purpose of subrogation waivers in construction contracts is to allocate risks among the parties to the contract. (Croskey et al., Cal. Practice Guide: Insurance Litigation (The Rutter Group 2008) P 9:116, p. 9-49 (rev. # 1 2008).) "Such agreements deter litigation and help parties avoid the cost of overlapping, multiple insurance policies." (Ibid.) Where a contractor causes a loss covered by property insurance, the insurer who has paid for the damages has no right of subrogation against the contractor because the waiver language waives the owner's claim. (Lloyds Underwriters v. Craig & Rush, Inc. (1994) 26 Cal.App.4th 1194, 1199.) "Viewed globally, these clauses make sense as an insurer on one project might very well be denied recovery by such a clause but benefit from the existence of such a waiver on another project." (4 Bruner & O'Connor, Construction Law (2008) 11:100.) Accordingly, subrogation waivers "are routinely upheld." (Ibid.) Form A201 evinces the intent to shift the risk of loss to insurance to the maximum extent possible: "The AIA has chosen . . . to put the ultimate loss on the property insurer . . . ." (Sweet on Construction Industry Contracts (2007) Insurance & Bonds, 22.04M, p. 783.) "The AIA has made a strenuous effort to bar subrogation claims by having participants waive any claims the participants may have against other participants." (Id. at pp. 779-780.) Whenever "loopholes" in the waiver have appeared, the AIA has changed its forms "to try to close" them and ultimately "to kill subrogation off." (Id. at p. 783; see id. at pp. 780-783.) California courts have consistently upheld subrogation waivers against challenges to their enforceability. (See Lloyd's Underwriters v. Craig & Rush, Inc., supra, 26 Cal.App.4th at pp. 1198-1201; Davlar Corp. v. Superior Court (1997) 53 Cal.App.4th 1121, 1124.)