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The 3 shell limit only applies to migratory birds. It has nothing to do with safety.
When I used to hunt Nevada for chukar I'm pretty sure you had to have the plug in.
I have used all manner of projectiles to take grouse, including, in no particular order, rocks, sticks, arrows, 22 bullets, and shotguns. Grouse taste good. I am grateful for the patient and not-so-wary nature of some of them so one of my limited skill could invite them to dinner.
IMO shooting a bird on the ground/water is akin to shooting a bedded big game animal. I'm not against either, but I prefer to shoot birds on the wing.