Druid Shapeshift ACF - aquatic form

[person29]

In a new campaign I am running one of my players is going to take the ACF from PHB2

We were discussing it to make sure we are on the same page with it and he brought up the possibility of an aquatic form being added. The beginning couple levels of the campaign will have a lot of aquatic opportunities but I wasnt sure how I would go about creating an aquatic form that would fit.

I figure a starting place would be very similar to aerial form for the plus to strength and armor class, a bite instead of a talon attack, and swim speed instead of fly. The real issue I run into is water breathing, since all the other forms breath air or don't need to breath it doesnt matter for them.

I feel like even giving it water breathing in that form isn't too game breaking unless I tried to drown the party or something, but I figure the playground is a great place to go for advice.

Thanks in advance

[Grod_The_Giant]

I'd probably allow him to take a feat of some sort. Say...

Aquatic Shapeshifter
Prerequisite: Shapeshift class feature
Benefit: Pick one alternate form you can assume via the Shapeshift ACF. When you assume the chosen form, you gain the Aquatic subtype, the Amphibious special quality, and a swim speed equal to you base land speed plus any speed boost granted by the form.
Special: You may take this feat multiple times, selecting a new form each time.