UNDERCURRENT  |  CNPS · May 15, 2026

California is moving multiple project-approval reforms at once — through legislation, a ballot initiative, agency processes, federal land-management changes, and a broader abundance / permitting-reform narrative. For CNPS, the near-term question is narrower: are the review standards that translate CNPS Inventory science into project-level conservation outcomes being clearly anchored before the legal and procedural baselines harden?

Three windows appear action-proximate. First, SB 954's rare-plant language has not yet been tested against CNPS Inventory ranks. Second, the WJTCA Program EIR baseline is being shaped before the draft is released. Third, the BLM Public Lands Rule repeal takes effect June 11, changing the management context for California desert rare-plant habitat and pending project authorizations. The value of this brief is not that any one item is hidden; it is that standard monitoring can treat them separately when the conservation consequence depends on how they interact.

The 30-second read

The signal: California rare-plant review standards are being shaped across several channels at once: SB 954 / SB 1097 / BACA, the WJTCA Program EIR, and federal land-management changes affecting desert habitat. The central CNPS question is whether CNPS Inventory-ranked plants are clearly represented in the definitions, baselines, and review triggers now being written.

Why it matters: Standard monitoring can track each item separately. The risk is that the standards translating CNPS science into project-level conservation outcomes may harden before the gaps are tested: SB 954 may be treated as a fix before its language is verified; the WJTCA baseline may be set before public comment; and the BLM rule repeal changes the management context on June 11.

Practical implication: The highest-leverage work may be pre-decision and pre-draft: language verification before Appropriations, Inventory data submission before the WJTCA draft EIR, and desert rare-plant posture review before the BLM repeal takes effect.

What to do with it: Use this as an expert-scrutiny prompt, not a final conclusion. The near-term decisions are whether to test SB 954 against CNPS Inventory ranks, whether to engage CDFW before the WJTCA draft baseline is codified, and whether the June 11 BLM deadline changes Chuckwalla / Soda Mountain posture.

This week, in order of urgency

1. Deadline: weeks SB 954 / SB 1097 / BACA — verify the rare-plant review standard before the legislative window narrows

The most immediate CNPS-specific question is whether SB 954 actually covers CNPS Inventory-ranked rare plants, especially Ranks 1B and 2B, or only taxa already captured by state / federal special-status definitions. SB 1097 and BACA add pressure on CEQA review standards and alternatives analysis for major project categories. Treat these as related review-standard shifts, but keep the claims separate: SB 954 is the language-verification task; SB 1097 and BACA are the broader review-threshold context.

2. Deadline: June 11 BLM Public Lands Rule repeal — reassess desert rare-plant exposure before the management context changes

The BLM Public Lands Rule repeal takes effect June 11, 2026. That change compounds with Chuckwalla monument litigation and pending federal public-lands legislation on the same California desert habitat base. The practical question is not whether every affected taxon lacks protection; it is whether ESA coverage can be assumed as a backstop for CNPS-ranked desert taxa. Specific taxa and listing status should be verified against CNPS Inventory and state / federal listing records.

3. Window: pre-release WJTCA Program EIR — engage before the baseline and checklist template are codified

CDFW is preparing a Program EIR for the Western Joshua Tree Conservation Act permitting program. The draft has not yet been released. If the EIR baseline and within-the-scope checklist are set without robust CNPS Inventory data for co-occurring rare plants, the gap could propagate across thousands of individual project reviews in the 9-million-acre study area. The pre-release scoping window is the higher-leverage moment.

ANALYSIS — SITUATION 1

The CEQA review standard is being changed in four places at once — and the rare-plant definitions are not anchored in any of them

Stage: Active · Direction: Constraining · Customer fit: Direct

SB 1097 is the most advanced of four mutually reinforcing tracks advancing faster project approval in California. The bill replaces the fair argument standard — the standard that requires an EIR when there is a fair argument that a project may have a significant environmental impact — with a "more likely than not" substantial evidence standard for solar, wind, energy storage, and specified overhead transmission projects. It also creates a full CEQA exemption for transmission maintenance, repair, reconductoring, and replacement within existing rights-of-way. A 270-day timeline for resolving legal challenges to qualifying environmental determinations is included.

The four channels and their functions: SB 1097 advances the statutory standard through the legislature. SB 954 is intended to resolve the "natural and protected lands" coverage gap from SB 131 that left CNPS-ranked rare plants outside its protected-lands definition — but whether its language actually covers CNPS Inventory-ranked taxa has not been confirmed against the Inventory's rank definitions. BACA would, if it qualifies for and passes the November 2026 ballot, eliminate the alternatives analysis requirement for "essential projects" — a category that includes housing, clean energy, transmission, water, transportation, and broadband infrastructure. The broader abundance / permitting-reform narrative provides the shared rhetorical frame positioning environmental review as obstruction of urgently needed projects.

Key implication: The SB 954 language question is the most immediately actionable item in this situation. If SB 954 is treated as having resolved the rare-plant coverage gap before its language has been tested against CNPS Inventory ranks — specifically CNPS Ranks 1B and 2B, which represent the taxa at greatest risk — advocacy attention will move on from a gap that may still be open.

Edison International & Affiliated Entities is present across at least two of these tracks as a matter of public record. Per FPPC filings, Edison contributed $2,000,000 to the Committee to Build an Affordable California, the BACA campaign committee sponsored by the California Chamber of Commerce. Edison's California transmission and distribution infrastructure — the largest investor-owned utility network in Southern California — falls directly within the project categories that SB 1097's transmission exemption and modified review standard would cover. These are separate facts stated separately. What they establish is that a single entity with material financial exposure to the outcomes of both tracks is present in both.

The compound is more durable than any individual track. If SB 1097 fails or is amended, BACA advances the same pressure through a voter-majority threshold. If BACA fails, the legislative track and the narrative frame remain. The four channels are mutually reinforcing in timing, framing, and political logic.

SB 1097 signal record

Stage: In Senate Appropriations

Trigger: Appropriations committee vote; floor vote; Governor's signature

If this holds: Fair argument standard replaced for covered project types; transmission maintenance CEQA-exempt statewide

System behavior: Botanical surveys and rare-plant expert testimony enter the process at a higher evidentiary bar for covered projects; opposition threshold for requiring an EIR increases

SB 954 signal record

Stage: Senate Appropriations — next month

Trigger: Appropriations hearing; CNPS language review against Inventory ranks

If this holds (unverified): Gap from SB 131 may remain open for CNPS Inventory-ranked taxa not captured by state/federal special-status definitions

System behavior: A gap treated as resolved may leave CNPS-ranked 1B/2B taxa outside operative protections; advocacy pressure dissipates before problem is fixed

BACA signal record

Stage: Circulating; approximately 1 million signatures reported; qualification under review

Trigger: Secretary of State qualification determination; November 3, 2026 ballot

If this holds: Alternatives analysis eliminated for "essential projects"; comment periods shortened; modified review process applies to a broad project category that includes most clean energy, infrastructure, and large housing developments

System behavior: Primary mechanism by which botanical surveys can force project redesign — alternatives analysis — is removed for the project categories most likely to involve habitat conversion

ANALYSIS — SITUATION 2

Three federal tracks are compounding on the same desert rare-plant habitat base — and the taxa most at risk have no ESA backstop

Stage: Active · Direction: Constraining · Customer fit: Direct

The BLM Public Lands Rule repeal, effective June 11, removes the regulatory framework that placed conservation on equal footing with extractive uses across approximately 15 million California BLM acres, covering desert and inland lands across Riverside, San Bernardino, Imperial, Kern, San Luis Obispo, and Ventura counties. The Chuckwalla National Monument — 660,000+ acres of botanically significant California desert — was rescinded in March 2025, with CNPS as an active litigant. A reconciliation bill provision moving through Congress includes a public-lands sell-off mechanism that, if enacted, would threaten public ownership of a portion of that base.

These should not be read only as three parallel developments. They compound on the same geographic footprint and the same taxonomic exposure. Many CNPS-ranked desert taxa likely affected by these management changes may not be ESA-listed. The specific taxa and listing status should be verified against CNPS Inventory and state / federal listing records. There is no species-level protection backstop when federal land management weakens. Monument protection, rule-based management standards, and public ownership were the three layers available for these taxa. All three are now under active removal.

Soda Mountain Solar is the first project-level test of what this compound means in practice. CEC certification was granted April 27, 2026, for a 300 MW solar and 1,200 MWh battery storage facility on 2,670 BLM-administered acres in San Bernardino County, adjacent to Mojave National Preserve. BLM authorization remains pending. That authorization will now be processed under the post-repeal management framework — without the science-based management standards the rule required.

Key implication: The Chuckwalla litigation addresses monument rescission. It does not address the BLM rule repeal management vacuum or the potential reconciliation sell-off. The litigation is one track of three. The June 11 effective date is the near-term pressure point that changes the management context within which all three tracks operate.

Federal desert rare-plant compound — signal record

Stage: Active (BLM rule, Chuckwalla litigation); moving (reconciliation bill)

Key trigger: June 11 BLM rule effective date; Chuckwalla litigation schedule; reconciliation bill floor votes

If this holds: Management vacuum over California desert rare-plant habitat deepens without ESA species-level backstop; Soda Mountain Solar BLM authorization proceeds under changed standards

System behavior: CNPS Inventory-ranked taxa in California desert communities lose the only institutional layers that provided project-review leverage; Soda Mountain becomes a precedent for post-repeal BLM desert project authorization

ANALYSIS — SITUATION 3

The WJTCA Program EIR baseline is being set before the draft — and that pre-release window is the leverage point, not the comment period

Stage: Emerging · Direction: Mixed · Customer fit: Direct

CDFW is preparing a Program EIR for the Western Joshua Tree Conservation Act Permitting Program, covering a 9-million-acre study area across Mono, Inyo, Tulare, Kern, San Bernardino, Ventura, Los Angeles, and Riverside counties. The Program EIR will do two things that compound in significance: it will codify the baseline environmental conditions against which individual project reviews are measured, and it will generate a "within-the-scope" checklist template that individual project applicants use to determine whether their project requires further review or qualifies as already addressed by the Program EIR. That template will govern rare-plant inquiry — including inquiry into co-occurring CNPS-ranked taxa — across thousands of individual project reviews before any specific project is submitted.

The CNPS Inventory is the most comprehensive source of rare-plant occurrence data available for the WJTCA study area. The Program EIR's baseline adequacy for co-occurring rare plants will be determined in large part by whether that data is incorporated into CDFW's scoping assumptions before the draft is prepared. A Fish and Game Commission effectiveness review of the Conservation Plan is also due in 2026; the fee schedule review is due December 2026.

Key implication: The comment period on the draft EIR is not the primary leverage window. By the time the draft is published, baseline assumptions will largely reflect decisions already made in CDFW's internal scoping process. The higher-leverage moment is before that — before the draft is released, while scoping is still open to external input. That window has no publicly announced close date, which means it is open now and may close without notice.

WJTCA Program EIR — signal record

Stage: Pre-release scoping; draft EIR not yet published

Trigger: Draft EIR release (date unconfirmed); public comment period opens

If baseline is set without CNPS data: Co-occurring rare-plant inquiry is systematically inadequate across thousands of individual project reviews in the 9-million-acre study area; checklist template propagates the gap

System behavior: Streamlined WJTCA permitting functions as a rare-plant data gap across the desert region; inadequate baseline becomes the legal standard for individual project review

Watchlist — monitor, not yet action-proximate

Prop 4 / 30x30 biodiversity appropriations (June 15 deadline): Prop 4's $1.2B biodiversity chapter is flowing year-by-year, creating annual substitution risk. CNPS's own 30x30 representation analysis identifies rare habitats and fine-filter species communities as under-represented. The gap between what that analysis shows and what this cycle funds without specific advocacy input is actionable before June 15. CNPS likely has high existing visibility on the budget process; the value-add is connecting the representation analysis to the specific appropriations decision window this cycle.

Wildfire-CEQA exemption pathway — structural embeddedness: Post-Palisades and post-Eaton executive orders have created a reusable institutional template for vegetation management CEQA exemptions. The "sensitive habitat" definition in that template is not anchored to CNPS Inventory ranks — mirroring the Situation 1 structural problem in a different channel. No confirmed near-term legislative window exists to address the non-coastal gap. The Coastal Commission's May 14 UCSC/CalVTP decision establishes that the Coastal Act ESHA standard is not displaced by CalVTP streamlining — a higher floor for the coastal zone, but not a fix for the non-coastal gap. Monitor for a legislative vehicle.

CAST invasive fire-adapted plants publication (May 6, 2026) — weak forward signal: A new science publication on invasive fire-adapted plants could, if adopted in agency guidance, provide a framing that expands the wildfire vegetation management exemption logic into post-fire restoration contexts where native plant restoration requirements would otherwise apply. No policy uptake signal confirmed. Flag for monitoring if the framing appears in CDFW or CalFire guidance processes.

Decision memo

1. SB 954 language verification — does it actually cover CNPS Inventory-ranked taxa?

SB 954 was introduced to address the "natural and protected lands" coverage gap from SB 131. Whether its language covers CNPS Ranks 1B and 2B plants — or only species already captured by state and federal special-status definitions — has not been confirmed. This is the most immediately actionable item in the brief. If SB 954 advances through Appropriations and is treated as a resolution before the language has been tested, the rare-plant coverage gap remains open while advocacy attention moves on.

Lever: Policy advocacy — rare-plant coverage in CEQA review

Window: Senate Appropriations — next month; legislative session closes September 12

Decision it should inform: Whether to commission a legal or policy analysis of SB 954's language against CNPS Inventory rank definitions before it is treated as a resolved issue

2. The four-channel CEQA architecture — does it warrant a coordinated policy, legal, and coalition response?

SB 1097, SB 954, BACA, and the abundance / permitting-reform are mutually reinforcing channels advancing pressure on CEQA's review trigger. Each serves a distinct function; the failure of any one does not stop the others. Edison International is present as funder in the ballot track and beneficiary of the legislative track. Whether this compound warrants a coordinated response — across policy, legal, and coalition channels — is a different question than whether each individual bill or initiative merits monitoring.

Lever: Policy advocacy + coalition coordination

Window: SB 1097 Appropriations now; BACA qualification period; session close September 12

Decision it should inform: Whether CNPS's legislative, legal, and coalition response to CEQA pressure should be framed around the compound architecture rather than individual bills

3. BLM rule June 11 effective date — does it change the Chuckwalla posture or create a Soda Mountain comment window?

The BLM Public Lands Rule repeal takes effect June 11, compounding with the Chuckwalla rescission and the reconciliation bill sell-off provision on the same desert rare-plant habitat base. CNPS is an active Chuckwalla litigant. Soda Mountain Solar BLM authorization is pending. The June 11 date is the hard near-term trigger that changes the management context within which both the litigation and the authorization proceed.

Lever: Litigation support + conservation science

Window: June 11, 2026 — BLM rule effective date

Decision it should inform: Whether the rule effective date changes the Chuckwalla litigation posture; whether to prepare comments on the Soda Mountain BLM authorization before the changed management framework takes effect

4. WJTCA Program EIR — should pre-release scoping engagement with CDFW begin now?

The EIR baseline and checklist template are being shaped before the draft is released. CNPS Inventory data is the directly relevant scientific resource for co-occurring rare-plant inquiry across the 9-million-acre study area. The pre-release window is open now; the close date is unannounced. Waiting for the draft comment period means engaging after the baseline is set.

Lever: Conservation science — Inventory data as baseline material

Window: Pre-release scoping; close date unconfirmed

Decision it should inform: Whether to initiate scoping engagement with CDFW before the draft EIR is released; whether to prepare a formal rare-plant data submission for EIR baseline development

5. Prop 4 appropriations — is the representation gap being translated into this cycle's budget advocacy?

The 30x30 representation analysis CNPS has produced identifies rare habitats and fine-filter species communities as under-represented. The June 15 budget deadline is the near-term window in which that analysis can influence appropriations decisions. The annual structure of Prop 4 biodiversity funding creates substitution risk each cycle.

Lever: Conservation science translated into appropriations advocacy

Window: June 15 budget deadline; Assembly committee markup active now

Decision it should inform: Whether CNPS's 30x30 representation analysis is being used as an input to specific appropriations recommendations in this budget cycle

What not to misread

SB 954 as having resolved the rare-plant coverage gap.

Correct read: SB 954 was introduced in response to the gap. Whether it actually covers CNPS Inventory Ranks 1B and 2B has not been verified against the Inventory's definitions. A bill that addresses the gap in title and intent but not in operative language resolves nothing — and if it is treated as a resolution, the gap persists unaddressed while the legislative session window closes.

SB 1097, SB 954, and BACA as three separate items to track independently.

Correct read: They are four mutually reinforcing channels — legislative, ballot, narrative, and capital — advancing pressure on the same CEQA review trigger simultaneously. Standard bill-by-bill monitoring will not surface the compound structure. The compound is more durable than any individual track: each channel provides a different pathway to the same outcome, and the failure of one does not stop the others.

ESA coverage as a backstop for the desert rare-plant taxa most at risk.

Correct read: The CNPS-ranked desert taxa most exposed to the federal management vacuum are not ESA-listed. Monument protection, rule-based management, and public ownership were the layers available. All three are under active removal simultaneously. There is no species-level protection fallback that activates when federal land management weakens for these taxa.

The WJTCA Program EIR comment period as the primary engagement window.

Correct read: By the time the draft is released for public comment, the baseline assumptions governing co-occurring rare-plant inquiry will largely reflect CDFW's internal scoping decisions. The pre-release scoping window — open now, with no announced close date — is where CNPS Inventory data has the most leverage over what standards get codified.

The wildfire vegetation management exemption as a resolved or case-specific issue.

Correct read: Post-Palisades and post-Eaton executive orders have created a reusable institutional template. The exemption will apply to future fire events automatically. The "sensitive habitat" definitional gap — not anchored to CNPS Inventory ranks — is embedded in that template. The Coastal Commission's May 14 UCSC/CalVTP decision establishes a higher floor in the coastal zone only; the non-coastal gap remains open and structurally embedded.

Confidence notes

SB 954 language covers CNPS Inventory Ranks 1B/2B

Evidence basis: Bill text review pending cross-check against CNPS Inventory rank definitions

Confidence: Open question

What would change this: Expert review of SB 954 operative language against CNPS 1B/2B taxa definitions

SB 1097 replaces fair argument standard for covered projects

Evidence basis: Bill text, leginfo.legislature.ca.gov; analysis confirmed in multiple legal commentaries

Confidence: High

What would change this: Amendment in Appropriations

BACA eliminates alternatives analysis for "essential projects"

Evidence basis: Initiative text 25-0023A1; Secretary of State circulating record

Confidence: High

What would change this: Initiative amendment or qualification failure

Edison contributed $2,000,000 to the BACA campaign committee

Evidence basis: FPPC Top 10 Contributors List, measure 25-0023A1, Committee to Build an Affordable California — direct public record

Confidence: High

What would change this: Correction to source record or committee filing amendment

Edison's CA transmission operations fall within SB 1097 covered project categories

Evidence basis: SB 1097 bill text (transmission maintenance/reconductoring exemption; modified review for overhead transmission lines) + Edison public service territory disclosures

Confidence: Inference

What would change this: This is an analytical inference from bill text and public service territory, not a stated financial interest; labeled accordingly

BLM Public Lands Rule repeal effective June 11, 2026

Evidence basis: Federal Register publication May 11, 2026; 30-day statutory period; confirmed by multiple independent sources

Confidence: High

What would change this: Legal injunction; nothing in current record suggests this

WJTCA Program EIR pre-release window is the highest-leverage engagement point

Evidence basis: Program EIR process design under CEQA; draft not yet released; scoping decisions precede draft preparation

Confidence: High as mechanism claim

What would change this: Draft EIR release (would confirm window has closed)

CNPS-ranked desert taxa most at risk are not ESA-listed

Evidence basis: CNPS Inventory data; structural observation about listing status for CNPS 1B/2B desert taxa

Confidence: Medium as structural claim

What would change this: Emergency ESA listing or petition for specific taxa

Soda Mountain Solar BLM authorization pending as of May 15, 2026

Evidence basis: CEC press release April 27, 2026: certified "contingent on BLM approval"; no BLM ROD found in public record

Confidence: High

What would change this: BLM Record of Decision issued

Coverage note

This brief draws from published legislative materials, agency records, Federal Register notices, public ballot initiative materials, campaign finance disclosures, conservation organization materials, and selected public narrative sources. Coverage is strongest where native-plant, habitat, CEQA, or public-lands consequences are visible through public records, bill text, agency processes, public filings, or recurring policy arguments. Coverage is weakest on private coalition dynamics, unpublished legal strategy, internal agency deliberations, local chapter intelligence, and rare-plant occurrence data not yet reflected in public records or the CNPS Inventory.

Sources

1. SB 1097 – California Environmental Quality Act: electrical distribution; clean energy; exemptions; standard of review. California Legislative Information / LegiScan bill text and bill history. Supports claims about SB 1097’s covered project categories, CEQA exemptions, modified standard of review, and current legislative status. https://legiscan.com/CA/text/SB1097/id/3405150?utm

2. SB 954 – California Environmental Quality Act: exemptions; natural and protected lands; advanced manufacturing facilities. California Legislative Information / LegiScan bill text and bill history. Supports claims about SB 954’s purpose, amended language, and the need to verify whether its operative language covers CNPS Inventory-ranked plants. https://legiscan.com/CA/text/SB954/id/3405128

3. Building an Affordable California Act / Initiative 25-0023A1. California Attorney General title, summary, and amended initiative language. Supports claims about BACA’s proposed CEQA modifications, covered “essential project” categories, public-comment changes, and streamlined alternatives-analysis process. https://oag.ca.gov/system/files/initiatives/pdfs/25-0023A1%20(%26quot%3BEssential%20Projects%26quot%3B).pdf?

4. Building an Affordable California signature submission. California Chamber of Commerce announcement, April 27, 2026. Supports the claim that the campaign began submitting nearly one million signatures for potential November 2026 ballot qualification. https://advocacy.calchamber.com/2026/04/27/affordable-ca-campaign-to-qualify-for-november-2026-ballot/?

5. BACA campaign finance – Edison contribution. California Fair Political Practices Commission, Top 10 Contributors List for November 2026 pending and circulating ballot measures. Supports the claim that Edison International & Affiliated Entities contributed to the Committee to Build an Affordable California. https://www.fppc.ca.gov/search-filings/top-10-contributors-list/november-2026-general-election/november-2026-pending-circulating-ballot/?

6. BLM Public Lands Rule rescission. Federal Register final rule, “Rescission of Conservation and Landscape Health Rule,” published May 12, 2026. Supports the claim that the rule rescission is effective June 11, 2026. https://www.federalregister.gov/documents/2026/05/12/2026-09386/rescission-of-conservation-and-landscape-health-rule?

7. Western Joshua Tree Conservation Act and permitting program. California Department of Fish and Wildlife WJTCA overview and permitting pages. Supports claims about CDFW’s WJTCA authority, permitting program, and local-agreement structure. https://wildlife.ca.gov/Conservation/Environmental-Review/WJT/WJTCA?

8. WJTCA Program EIR. California Department of Fish and Wildlife Program EIR materials for the Western Joshua Tree Conservation Act permitting program. Supports the claim that the Program EIR is designed to streamline CEQA review for individual WJTCA incidental take permit applications. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=238471&inline

9. Soda Mountain Solar Project. California Energy Commission project page and April 27, 2026 approval announcement. Supports claims about CEC certification, project scale, location, opt-in certification process, and remaining BLM approval relevance. https://www.energy.ca.gov/news/2026-04/cec-approves-soda-mountain-solar-and-battery-storage-project-san-bernardino?

10. Chuckwalla National Monument litigation. CNPS and Earthjustice materials on intervention in litigation challenging the monument designation. Supports claims that CNPS-aligned conservation organizations are defending the monument and that litigation seeks to undo the January 2025 designation. https://earthjustice.org/press/2026/court-allows-organizations-to-intervene-in-lawsuit-to-defend-chuckwalla-national-monument?

11. CNPS Rare Plant Inventory and California Rare Plant Ranks. CNPS Rare Plant Inventory and California Rare Plant Rank definitions. Supports claims about CNPS Inventory use, CRPR 1B / 2B definitions, and the need to test statutory language against Inventory-ranked taxa. https://www.cnps.org/rare-plants/cnps-inventory-of-rare-plants?

12. CNPS 30x30 / biodiversity representation analysis. CNPS 30x30 midpoint assessment and biodiversity initiatives materials. Supports claims about biodiversity representation gaps, rare habitats, species richness and rarity, and the role of 30x30 in native biodiversity conservation. https://www.cnps.org/artemisia-journal/californias-30-x-30-initiative-at-its-midpoint-44874?

Companion sources document: Undercurrent_CNPS_sources_2026-05-15.md

Undercurrent.is - CNPS - May 15, 2026