CA is now all non-tox, all the time, for all game. So, last time I hunted wild pheasants with a 20 gauge, I used 3" Black Cloud #3. There were two of us, no dogs, myself with a 20 and buddy with a 12, both shooting steel. Neither of us was getting clean one-shot kills. Last pheasant I shot that weekend took five shots to anchor the bird. Crossing shot at 35 yards knocked him down, second shot slowed him on the ground, third shot slowed him some more, next two kept him from getting into the deeper cover. All five shots were on the money and at a reasonable range. These were big, mature birds, but steel is not a good choice. Same area a couple of years before that, I was getting clean kills with 2-3/4" lead #4s. If you want to shoot non-tox with a 2-3/4" 20, select your ammo carefully.