Hmm, Tribble's system cuts out at 25HD.

At that point HD doesn't really make as much of a difference...

What about after 25HD divide it by an extra .5 per HD instead of every 5? (as every other puts this at 21 still, but might work better in general)


That would put the cloud Ray at: ~17. Seems more accurate to me.
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435 divided by 9: 48.333 (about 48)
Armor Class: 8 (-0)
Special Attacks: Swallow whole (+1)
Special Qualities: darkvision 60 ft, levitation, low-light vision, protection from arrows, telekinesis (+3)
Bonus Feats: It actually requires many more feats than it has (+0)
52 divided by 3: 17.33 etc...