This may seem easy but I don't think it is since the game probably has fixed slots in memory for these (not 100% sure)
This card takes too much investment to be worth running over other water-type Pokmon
For instance, Coalition Victory requires eight mana and your commander to be out to win, while Gifts Ungiven is effectively either a combo piece in high-powered decks, or a fun alternative to Fact or Fiction anywhere else
Years after the beginning of my professional Magic design career, I found out that I was going to lead the design of the Warhammer 40,000 Commander decks
It has 100 HP and a weakness to Water, and is closely based on Ninetales from Base Set
Notably, the difference between playable Tier 1 and 2 decks is lower than usual, so this doesnt mean the deck cant pick up sets against Altergeist and Dark Warrior