I'd leave the final decision up to a GM. some people have listed techs, others don't. It's not like you can't make up a new one if the situation calls for it, so long as it's not a complete ass-pull though. Like, if Zell used a rapid-flurry technique, even if you hadn't listed him as having it, that's reasonable.

On the other hand, using his power to form helicopter blades and start flying might need a bit of training and a suitable moment of inspiration or desperation.