The lake at that time still had thick wetlands fringing the shores and it continued to attract large numbers of migratory birds. In order to protect the birds from duck hunters and stop the noise and danger of gunfire so close to the city, Dr. Merritt proposed to turn the lake into a wildlife refuge in 1869. The state legislature voted Lake Merritt Wildlife Refuge into law in 1870, making it the first such refuge in North America. No hunting of any sort was to be allowed and the only fishing was to be by hook and line.