What is the applicable limitation period for an action alleging that negligent construction of a foundation caused irreparable damage to a home?

The parties agree that the matter is governed by the three-year statute of limitations in section 338, subdivisions (b) and (d). ³ "The orthodox rule in tort actions is that the applicable limitation period will run from accrual of the action 'upon the occurrence of the last element essential to the cause of action.' [Citation.] In the case of injury to real property, the orthodox rule would dictate that 'if the defendant's act causes immediate and permanent injury' to the property the statute would run from the date of the act. [Citation.]" (CAMSI IV v. Hunter Technology Corp. (1991) 230 Cal.App.3d 1525, 1534, 282 Cal.Rptr. 80.) The harm must be actual and appreciable harm to the property. (Ibid.) In the instant case, the harm to the property was allegedly caused by negligent construction of the foundation and inadequate compacting of the soil on which the residence was built. These harmful acts occurred at the time of construction of the home in 1982.