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the lack of a Ghostly Prison or Sphere of Safety-type of effect that keeps the opponent from being able to attack you hurts a great deal

This is a commander that also incidentally works well for all the rest of the traditional sans-blue win conditions as well, with Hoarding BroodlordHoarding Broodlord lines being particularly interesting

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And if not, even Trample sometimes will let you satisfy the condition and get you that Energy

Pidgeot ex also has 280 HP, which isn't the highest but is enough to keep it in play

As an additional cost you also need to exile x cards from your graveyard