What is the test for cause of action against a contractor who has substantially completed construction?

The majority relies on State of New York v. Lundin, 60 N.Y.2d 987, 471 N.Y.S.2d 261, 459 N.E.2d 486 for the proposition that plaintiff's cause of action arose when it had performed the contract by substantially completing construction (majority opn., p. 951, 475 N.Y.S.2d p. 245, 463 N.E.2d p. 586). This application overlooks that, at that point, no breach had occurred because defendant had not yet refused to pay the money requested. The critical inquiry is: When did a defendant substantially complete its performance so that a breach has ripened into an enforceable action? In Lundin, where an action was brought against the contractor for defective construction, the cause accrued when the contractor declared the work complete. Here, where the action is against the owner for payment, no cause accrued until the owner refused to pay all that was requested. The substantial performance at issue is not that of plaintiff, but of defendant. And defendant did not substantially perform its obligations until it completed its audit of plaintiff's final requisition.