Ehhh, still around the decent card era as it seems.
100 HP is great for a stage 1. The weakness to water kind of hurts, the resistance is wonderful, and the retreat cost is just heavy.
So, its first attack, for three energies, does 50 and resistance isn't applied. Now the energy cost is expensive, but you got DCE to help you here. Furthermore, an attack that doesn't apply resistance is pretty good. The second attack costs four energies, does 70, requires you to flip two coins, and does 70 times the number of heads. Well, this attack is quite expensive, but yet again, DCE helps here. The flippiness, though, is kind of risky.
Overall 4/10 in modified
Well, this card isn't too bad. It is fairly decent actually. Since we have DCE out right now, this Donphan has a fair boost. Furthermore, lightning resistance is great. The reason why the rating isn't so high sadly is because of decks like Kingdra and Gyarados, heavy retreat cost, and being flippy and risky.