Should the golden paintbrush have been delisted as an endangered species?

Key scientists who worked on the plant’s assessment say no, and they could have the numbers to prove it

Ready or not: The federal government says golden paintbrush are doing well. Others, not so much. Photo: Mosa Neis/Pacific Rim Institute

By Nathan Gilles. June 13, 2024. Last summer, on the cusp of the fiftieth anniversary of the landmark Endangered Species Act, the U.S. Fish and Wildlife Service celebrated a “ conservation success story ” by removing the golden paintbrush from the federal endangered species list.

The column-like flowering stalks of the golden paintbrush ( Castilleja levisecta ) were once a common site in prairie habitats in Oregon’s Willamette Valley, Washington’s Puget Sound Trough and sections of western British Columbia.

But by the mid-1990s, it was clear the species was in trouble.

When the golden paintbrush first received ESA protections in the late 1990s, fewer than 20,000 plants could be found at just 10 locations in Washington and British Columbia. In Oregon the species had been extirpated.

For over two decades, the USFWS worked with independent scientists to bring back Oregon’s lost populations through direct planting and seeding.

Washington’s dwindling wild populations were also augmented in this way, as were new golden paintbrush population sites in the state.

As a result, by 2023 when the species was delisted, the USFWS could boast “over 325,000 plants at 48 locations” across the plant’s native range in Oregon, Washington and British Columbia.

According to the USFWS, these numbers demonstrate that the species “no longer meets the definition of an endangered or threatened species under the [Endangered Species] Act.”

While the USFWS and local media celebrated this “success story,” not everyone agreed with the decision to delist the paintbrush and how the USFWS interpreted those population numbers, including the independent scientists who counted and planted the plants. ( Columbia Insight was among those celebrants when the proposal to delist was first announced in 2021 .)

According to interviews conducted for this story and public comments posted to the Federal Register , the most noteworthy critics of the USFWS’s decision to delist the golden paintbrush were and remain the region’s leading golden paintbrush experts.

Assembled by the USFWS, these independent experts made up the golden paintbrush technical advisory team.

The team created multiple reports and peer-reviewed studies, providing the bulk of the “best scientific and commercial data available concerning the status of the species” that the agency used to argue that the golden paintbrush no longer needed ESA protections in its final decision on July 19, 2023.

Technical advisory members, however, unanimously opposed and continue to oppose delisting, claiming the USFWS misinterpreted the science they created at the agency’s behest.

Good host: The rare and endangered Taylor’s checkerspot butterfly lays its eggs on golden paintbrush. The eggs hatch and the larvae feed on the plants. Photo: Tom Kaye

Andrew LaValle, public affairs officer at the USFWS Pacific Region Office in Lacey, Wash., declined Columbia Insight ’s request for an interview for this story, referring instead to the agency’s 2023 delisting decision.

While the advisory team’s arguments against delisting can get into the scientific weeds, at the heart are years of data suggesting that despite large, range-wide population numbers, many individual sites with golden paintbrush populations should not be considered “stable” or capable of reproducing on their own.

According to team members, the issue isn’t so much about that impressive total number—those 325,000 individual plants range-wide—as it is about how those 325,000 plants are distributed between those 48 population sites. And how that 325,000 number was arrived at.

Looked at this way, that large number is far less impressive.

Scientists working at natural resource agencies in both Oregon and Washington share these concerns, and both states continue to provide protections for the species at the state level despite the USFWS decision to delist.

Technical advisory team members say the issue of whether populations can be considered stable dates to 2021, when the USFWS first proposed delisting.

According to team members, the USFWS inappropriately and prematurely included the large number of planted golden paintbrush plants in the agency’s arguments to delist the species.

Counting plants, planting plants, counting planted plants

Although in 1997 there were fewer than 20,000 flowering paintbrush plants, by 2018, that number had risen to 562,726 individuals, thanks to scientists working with the USFWS.

Peter Dunwiddie, an affiliate professor in the Department of Biology at the School of Environmental and Forest Sciences at the University of Washington, and a member of the golden paintbrush technical advisory team, was at the forefront of the recovery effort.

Dunwiddie began monitoring the golden paintbrush in 1996.

When the plant received ESA protections the following year, he became deeply involved in the species’ recovery.

This included helping write the species’ recovery plan for the USFWS and helping implement that plan with agency funding by “outplanting” the species—with both nursery-grown “plugs” and by broadcasting seeds—at suitable prairie sites.

Down to earth: Peter Dunwiddie in Cambodia. Photo: Peter Dunwiddie

Dunwiddie says he was and is still opposed to delisting.

“I thought it [the decision to delist] was premature for a number of reasons,” says Dunwiddie. “Things are never static in nature. Things are always changing and there are various problems that only became evident over time.”

Dunwiddie says that although the species in general was doing fairly well when the USFWS proposed delisting in 2021, he still thought there were some clear “red flags.” His concern: it was just too soon to make the call.

He wasn’t alone.

In a joint letter to the USFWS written in August 2021, Dunwiddie and two other advisory team members argued that the agency didn’t have enough long-term population data to demonstrate that outplanted populations were getting pollinated and naturally spreading their seeds and reproducing.

Time, numbers and golden paintbrush biology were at the heart of their argument.

Dunwiddie says that although the effort to recover golden paintbrush with outplantings began in the early 2000s, it actually took years to figure out how best to establish outplanted populations. Consequently, he says, the majority of successful outplanted plants weren’t established until the period between 2011 and 2015.

The problem, Dunwiddie and colleagues argued in their letter, is that the USFWS’s 2021 proposal to delist relied on population data that ended in 2018, stating that the “data on hand are insufficient to conclude that these outplantings have reached an equilibrium and are now stable or increasing.”

This dataset, Dunwiddie and colleagues argue, simply didn’t cover a long enough period of time, and it didn’t fully consider the plant’s life span.

Individual golden paintbrush plants live on average about five years—with some living as long a decade or longer.

It also takes two to three years for plants to flower. This means a large number of plants counted in 2018 and used as an argument for delisting were flowering plants between three to seven years of age. (Flowering plants are counted because they are both sexually mature and easier to see.)

All this suggests, says Dunwiddie, that at least some of the golden paintbrush plants counted in 2018 and used to argue for delisting were planted by people and were not evidence of natural reproduction.

Technical advisory team member Adam Martin, an applied ecologist and conservation science project manager at the Ecostudies Institute in Olympia, Wash., shares Dunwiddie’s views.

“Some [individual plants] can live upwards of 10 years, some probably longer,” says Martin. “But most of them probably live less than five years. And it takes a couple years for them to flower, so you really can’t tell how well a population’s doing until probably seven to 10 years [after planting].”

Martin worked on both the plant’s recovery and counting efforts. He didn’t join Dunwiddie in his 2021 letter opposing delisting but did write his own letter addressing many of the same concerns.

Martin’s letter asserts that the USFWS misread the large population numbers to mean that populations of the golden paintbrush were now stable and able to reproduce on their own.

What they were more likely counting, according Martin’s letter was, “little more than a garden plant.”

“High watermark,” population declines

As Dunwiddie and colleagues note in their letter, 2018 was also a peak year for golden paintbrush populations range-wide in Oregon, Washington and British Columbia.

But those high numbers didn’t last.

By 2019, golden paintbrush populations had declined by 42% range-wide, falling to 325,320 flowering plants. (This 2019 number appears to be the source of the “325,000” plants cited in public statements made in 2023 by the USFWS.)

Survey numbers for 2020 estimated range-wide golden paintbrush numbers at around 370,000 plants, an increase from the previous year but still down from the 2018 peak of 562,726 flowering individuals.

This survey data, however, was incomplete due to COVID-19 restrictions.

Under cover: Golden paintbrush can carpet landscapes in unique and beautiful patterns. Photo: Tom Kaye

The problem with using such a short dataset, says advisory team member Walter Fertig, is populations of golden paintbrush often balloon following planting only to level off or even decline if given enough time.

Fertig, a conservation biologist and then the lead state botanist for Washington’s Natural Heritage Program, which oversees the state’s own list of rare and endangered species, joined Dunwiddie in his 2021 letter.

“Many of [the outplanted populations] have been quite successful, at least initially,” says Fertig. “But then they can start to decline. I think they [USFWS] liked the 2018 data because that was the high watermark.”

Fertig calls the decision to delist “premature.”

In a 2021 comment letter to the USFWS, Fertig, who now works at Washington State University as collections manager for the university’s herbarium, pointed out that the 2018 dataset no longer represented what was currently happening at individual population sites.

In essence, Fertig’s argument accuses the USFWS of trying to sidestep the rules established in its golden paintbrush recovery plan.

The rules state that for an individual population of golden paintbrush to be considered “stable” it needs to have a five-year running average of at least 1,000 individual flowering plants.

This requirement is coupled with an additional rule that states that for the overall recovery effort to be considered successful, the species as a whole needs to have at least 15 stable populations that are also protected from development in some way.

In its proposal to delist, the USFWS, using 2018 data, estimated that range-wide there were 23 golden paintbrush populations that met the five-year population average, 15 of which were protected from development.

Fertig, who had been counting golden paintbrush plants and submitting his results to the USFWS in official reports to the agency, cried foul.

In his 2021 letter to USFWS he submitted his own numbers based on more up-to-date data, estimating that only 11 populations met the recovery plan’s requirements.

Dunwiddie and Fertig’s joint letter makes the same point, accusing the proposal to delist of walking “an uncomfortable balance between meeting some recovery criteria and rejecting others with unclear or missing justifications.”

Possible causes for decline range from climate change to being eaten by deer, voles and rabbits.

In its final 2023 decision, the USFWS responded to these criticisms by first revising the number of stable populations based on more up-to-date data, admitting not enough populations met the recovery criteria, and then arguing it didn’t need to use the golden paintbrush recovery plan in its final decision to delist.

The 2023 decision reads: “As of 2020, 17 populations averaged at least 1,000 individual plants per year over the 5-year period with most recent data from 2016 to 2020 …” However, the decision goes on to acknowledge that not enough of these populations were protected, noting that, “This recovery criterion has not been met as phrased in the recovery plan …”

Referring to recovery plans as “nonbinding documents,” the delisting decision then responds to assertions that the golden paintbrush recovery didn’t meet its plan’s criteria.

“Recovery plans provide roadmaps to species recovery but are not required in order to achieve recovery of a species, or to evaluate it for delisting,” the decision reads.

Fertig says he hasn’t read the final decision to delist.

The USFWS did, however, send an official letter to the Washington Department of Natural Resources responding to Fertig’s 2021 comments. The letter is dated July 31, 2023, 12 days after the agency posted its decision to delist to the Federal Register. The letter covers many of the same points as the delisting decision.

“In that letter, they’re basically saying, ‘Oh, they’re disagreeing with me, they’re throwing me under the bus,’ but they’re also basically using a lot of the same things that I pointed out, too. It was a master class in doublespeak,” says Fertig.

Population declines, taking the foot of the gas

To add fuel to the fire, outplanting continued through 2019 in Oregon and continues to this day in Washington, though at a much smaller scale than it had from 2011 to 2015, according to advisory team members.

This, Martin contends, further inflated population numbers.

“Of course, if you keep adding seeds, the [population] numbers are going to keep going up and up and up and up, and it’s going to look great,” says Martin. “But that’s not because populations are necessarily spreading and establishing. It’s just because you keep adding more [plants].”

Technical advisory team member Tom Kaye, executive director and senior ecologist at the Institute for Applied Ecology in Corvallis, Ore., has the same concern.

Kaye and his organization worked on the outplanting effort in Oregon and counted plants for the USFWS.

Kaye, who joined Dunwiddie and Fertig in their critical 2021 letter, was initially reluctant to comment on an effort he put so much time and energy into and an agency that continues to fund his organization.

But when asked about his letter with his fellow scientists, he stood by it.

“You can’t start counting until after the last planting has happened. You can’t look at trends in any rational way until you’re done planting,” says Kaye. “It’s like we’ve got our foot on the gas. We’re pushing this population or that population. It may be growing, but that’s because we keep putting more plants out.

It’s not necessarily growing on its own. We need to know what happens when we take our foot off the gas.”

Groundwork: Tom Kaye places captively reared caterpillars of Taylor’s checkerspot butterflies in a restored prairie in Oregon. Photo: Tom Kaye

With the outplanting effort now over in Oregon and significantly smaller than it had been in Washington, that “foot,” as it were, is no longer as firmly on the gas.

Whether or not current population numbers show what happens when outplanting stops or slows is unclear. What is clear is some populations continue to show declines.

In a report written in November 2023 for the USFWS, Kaye and colleagues at IAE detail population data from surveys taken in Oregon last year.

According to the report, Oregon’s total golden paintbrush population numbered 198,569 individual plants last year, down from its 2018 peak of 364,806 individual plants.

The report was written as part of the USFWS’s efforts to continue monitoring the species following delisting. Post-delisting monitoring will occur every two years and is set to expire in 2027.

This range-wide number, however, doesn’t illustrate what’s happening at each population site.

Seeming to verify earlier concerns, Kaye’s 2023 report notes that of the 10 populations in Oregon that previously exceeded the recovery plan criteria in 2019, only two grew last year. The other eight have declined.

New numbers in Washington tell a similar story, according to a draft of a yet-to-be-released report from Washington’s Natural Heritage program obtained by Columbia Insight through a public records request.

The report, like Kaye’s report, is part of the delisting monitoring program. It estimates that Washington’s total golden paintbrush population numbered roughly 200,000 plants in 2023, down from a peak of 400,000 in 2022.

Range-wide, the report estimates the population of golden paintbrush peaked in 2022 at 600,000 plants, slightly surpassing the previous peak in 2018.

The 2022 peak, the report notes, was due entirely to outplanted populations. Washington’s last remaining wild populations have been declining since 2011, reaching “critically low levels in 2023,” according to the report.

As for the state’s 18 outplanted sites, 12 have experienced declines from previous highs set in the 2010s, according to data published in the report.

Washington and Oregon weigh in

The Washington report was cowritten by Adam Martin and Jesse Miller. Miller, a botanist and ecologist, now fills Fertig’s old position as the state of Washington’s lead botanist.

In an email to Columbia Insight , Miller wrote that a population decline was “nothing to be concerned about in and of itself, but it does mean that the population sizes that were used to justify delisting are not representative of the populations that will be present on the landscape long-term.”

“While initial results of golden paintbrush outplantings are encouraging,” Miller continued, “I believe it is too early in the restoration process to assess the success of the restoration.”

Echoing Fertig, Kaye, Martin and Dunwiddie, Miller expressed concerns that there wasn’t sufficient evidence to suggest that some populations were in fact self-perpetuating.

“Most importantly,” wrote Miller, “we do not yet have good data indicating whether the planted populations are reproducing. I do not think we can call the restoration a success until we have some evidence that they will sustain themselves over the long-term.”

In an email to Columbia Insight , Michael Kelly, spokesperson for the Washington Department of Natural Resources, confirmed that the WADNR continues to stand by Fertig’s assertion that “delisting was premature.”

The state of Washington continues to list the golden paintbrush as a threatened species.

Troy Abercrombie, plant program manager for Oregon’s Native Plant Conversation program, and Jordon Brown, lead conversation biologist for the program, oversee Oregon’s Threatened and Endangered Species List.

Abercrombie and Brown responded to Columbia Insight ’s questions in a joint email.

The two scientists wrote that the state of Oregon “supports the independent decision making of the US Fish and Wildlife Service (USFWS) and has not taken a formal position on the federal delisting.”

However, when asked if their program supported the USFWS’s decision to delist the golden paintbrush, they responded, “No. We have concerns about the stability of existing populations, even in ‘recovered’ sites.”

“While we expect natural variability in any population of any species, significant and rapid declines in populations of golden paintbrush are concerning and indicate that they continue to face threats,” wrote Abercrombie and Brown.

Reasons for declines?

Exactly why some golden paintbrush populations might be declining remains a mystery.

Possible causes range from climate change to being eaten by deer, voles and rabbits.

The 2023 decision to delist concludes that the threat of predation by herbivores is not a “current or future threat” to the species.

The decision also appears to brush aside the importance of a 2019 report written by Fertig for the USFWS that concludes that the golden paintbrush is “ Highly Vulnerable ” to climate change.

The decision concludes that, “climate change does not currently pose a threat to the golden paintbrush, nor is it likely to become a threat to the golden paintbrush in the foreseeable future (next 30 years).”

As for why the USFWS made the decision to delist the golden paintbrush, technical advisory team members either said they didn’t want to comment or they could only speculate.

Fertig was the most outspoken of the bunch.

“I’m sort of just conjecturing, but I think there was pressure to show the success of the Endangered Species Act from the top down from within the agency,” says Fertig. “They want to demonstrate that the Act is working by removing the very protection that the Act enables, which is sort of counterintuitive.”

To date less than 6% of all species listed under the Endangered Species Act have been delisted.

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