Celebrim
Legend
Whenever there's ambiguity, if one interpretation would be problematic, it's preferable to use the other interpretation. It's far from clear that the Pearl is intended to not cost an action.
I would go further. It's fairly clear that the Pearl is intended to cost an action. Use activation is not inherently without an activation cost. The description of use activation in the SRD makes this clear.
In general, a use activated item only takes no action to use if it already requires some other action to use it. That is to say a use activated item either requires a standard action or it requires no additional action beyond the one implied by its use. If the use activated item does not require an explicit usage action to use it (swinging a sword, quaffing a potion, putting on a ring), then the use activated item usually requires a standard action to use. We'd generally expect in the Pearl of Power's case that it would specify no action is required to activate it if that were the case, but instead it specifies (with admittedly and unhappily technical language) that a command is required.
However untechnical the wording, I think it is obviously intended from the wording for the Pearl of Power to require a standard action along with a conscious mental command to use it.
It's like the crystal shard spell, which deals piercing damage that ignores DR because it's technically coming from a spell and all spell damage technically ignores DR. There was clearly some sort of miscommunication between the designers of the various sub-systems.
Not that it matters, but personally I think it's absurd that spell damage ignores DR in the first place. But that's a different situation. You can't know if the designer of crystal shard knew that spell damage bypassed DR and intended the effect. I think Pearl of Power is obviously using an action within the rules as written and wouldn't bow to a rules lawyer with a different interpretation. But with the crystal shard case, the rules lawyer is obviously correct assuming we've agreed that Psionic powers adhere to the rules for spells unless otherwise stated (psionic-magic transparency). The rules may be ill-considered, but at least they are clear.
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