Quote Originally Posted by upho View Post
First, I think you may have missed a very important sidebar found on three different pages, because Orcus doesn't have those abilities in all forms, and in a real game I think you'll agree it would be highly unlikely he'll have any of them when facing PCs who have managed to find his lair
Hm, well poor editing one way or the other, since under Orcus’s actual entry specifically:
Spoiler: Orcus entry, Book 2
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In All Forms: Orcus has the following abilities regardless of his condition:
... <many abilities snipped>...

Summon Undead (Sp): As their prince, Orcus can automatically summon up to 100 HD of any type of undead each day. This ability is the equivalent of a 9th-level spell.



Second, in the hypothetical scenario of a lone high-op PC facing Orcus at full power, I doubt even the most powerful of these abilities will necessarily have enough impact to actually alter the outcome of the fight:
Spoiler
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Practically any PC build I can think of which could achieve the combat values required to stand a chance against Orcus himself would barely register 3 balors, as their combat stats simply aren't high enough to matter. And 7 mariliths would probably have about as much impact on the outcome as 7 goblins.

Yes, if this works as you say, it could definitely make the fight incredibly difficult, if not flat-out impossible if the GM knows how Orcus can get the most out of it. However, per RAW I believe summon (Sp) abilities can only summon generic creatures, never unique individuals (just as the SM line of spells the ability is based on), which of course limits the customization possibilities of the summoned undead significantly and in turn their usefulness.
I wasn’t even considering the case of any lone PC *or* party reaching Orcus at full power, if for no other reason than that presumably anyone seeking to face Orcus (1) had to level up somewhere (2) has no objection to ridding the world of one of Orcus’s major cults (3) if having anything like the knowledge necessary to face Orcus, will have learned/researched/divinationed/Knowledge-cheesed their way into knowing about Orcus’s temples, or else, are just 100% completionist adventurers, right down to the silly goblin city.

Additionally, I wasn’t really worried about ridiculously epic PCs (solo or party) given that “balance” and “epic” seems... no... to me. (Plus, Orcus’s stats barely seem to make much use of Epic, despite the purported CR.) I was more interested in what seemed to be claims here that ~20th level PCs could defeat or even curbstomp Orcus as presented, and in that case...

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...if we are talking about anything close to 20th level PCs, multiple balors certainly aren’t nothing.

Additionally, RA’s text in the 3.5 version of level 15 specifically allows Orcus to summon specific templated undead: “Orcus prefers to summon shadows, as he can summon a large number of them and they are unturnable and can gang up on his enemies and drain Strength. He also likes to summon vampires (Ftr18, with appropriate equipment such as +3 armor and +3 weapons; or Clr16, with similar equipment).” If Orcus can specifically summon vampires with class levels, presumably he could just concentrate on full-caster liches instead, never mind whatever other templated/advanced/class-leveled casting-undead are available....

This assumes that Orcus’s “in all forms” explicit stats trump the sidebar notes. Losing such massive summoning AND 9th level spells would seem a bigger blow to Orcus’s power and CR than the authors would seem to think, admittedly....