I would tend to agree, any feat has to be manifested as a feat. In
our case we've used a few as stand alone items -- usually wnen
competeing directly against annoying magics (Fight Element).
using it to just do something appropos is fine...
ITs called improvising a feat -- using Fire to light the campfire would be fine (Fire Affinity, Make Fire feat improvised at -3)
The improv penalty is a -3, NOT -5. Its been updated in the FAQ.
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