I thinking of building a team with Waldo Arms, and I realized I don't know how "Incapacitate as FREE" works now since Incap is an attack modification not an action.

The most sensible change is probably "FREE: Make a close or range attack using incapacitated" with a possible addendum "you can use substute normal damage with any other effect during this attack" (to avoid things like using this to use BFC, CCE or RCE".

But has there been anything official or semi-offical?

Thank you.