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In One Piece, Marco has the rare power to transform into a phoenix, granting him the ability to fly like a bird and heal from his wounds.

In episode 463 of the One Piece anime, Marco is shown guarding against an attack from Admiral Kizaru. This is when his phoenix powers are first revealed. In this moment, his wings are the only parts of his phoenix form that are manifested so far. However, he isn't flapping them, yet he's somehow able to still hover in the air in front of Kizaru and have a conversation with him. He's been shown flapping them in other instances, but there are also scenes where he's able to fly without flapping them.

Is he actually able to fly without flapping his wings, or is it just the animation studio being lazy?

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I'm pretty confident that the reason here is indeed limited animation and not the actual way Marco flies. In exactly the same way, you don't see Monet flap much her wings in episodes 612-613 for example.

It might result from or just be confused with laziness, as you mention. Don't forget, though, that anime isn't just a story, it is also the entire team behind it, their short deadlines (often one episode a week!) and limited budget, artistic considerations...

Originally limited animation was not only a budget-saving choice, but a stylistic one as well.

...cultural aspects and a few more relevant parameters, all of which influence the final product.

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