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Actually, to inflict confusion on three enemies? Yeah, he does have to pay an action a turn.
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And Impact has to pay 4 actions for each confusion, and then has to pay an action a turn indefinitely, unless he ends the thing. Confuse ray comes out to 3 actions. Admittedly, pokemon actions, which're worth about 2.5 tactions each, I'd say. So you come out at 7.5. Impact comes out at 12, and that's not even considering that he has an ongoing freaking cost. Not overpowered in the slightest.
Other than that, I think we've reached the point where this isn't productive anymore at all. If you wanna object to specific techniques or make suggestions, do so. but this has been going on waaaaaay too long.