Do you really think the extra 16-21 damage on the odd crit will quickly lead to party deaths? I don't think so!
What are you basing that number on? If we go with something like the PC crit system for magic items, a 25th level monster should be rolling an extra 5-6 d6's on a crit. So let's call it 5.5d6, average of 3.5/roll for a total of 19.25. However, since we're rolling dice, we should take the maximum value into account, because this is what will cause the PC deaths. That would come out to about 33 damage. This is also on top of whatever damage they're already doing, which means we're talking in the neighborhood of 50-60 max damage. That's a third of a PC's hit points, even at Epic.
For a great example of what I mean, look at this example I already gave:
Yeah, I think that's something that's missing out of this. Part of the difference between PC's and Monsters is that a lot of monsters already roll a pile of dice to begin with...and then that pile gets maxed. Take an Ancient Red Dragon, for example. It's a Level 30 Solo Soldier whose At-Will Claw attack does 2d12+12 + 6d6 Fire Damage. On average this comes out to 13+12 + 21 Fire Damage, for a total of 46 damage. On a crit, that pile becomes maximized and we get 24+12 + 36 Fire Damage for a total of 72.
So, the crit damage is already 72 HP, which is enough to bloody some PC's in a single hit. With additional crit dice you'd see an average of 91 damage, with a max of 102. Remember when I calculated the HP of a Cleric with 12 CON at Epic? He had 144 HP without Toughness, since that's usually more of a frontline feat. So, if that Dragon crits him under the current rules while he's at full HP, he'll be bloodied. With your proposed modification he can be 20 HP
over his bloodied value and get dropped by an
average roll of the crit dice.
True, that's a Solo there...but the same still applies for normal monsters. A monster that does 2d6+10 or something? By adding crit dice you're essentially matching the base value of the maximized damage roll. That's a large increase for a monster, and means that they become very unpredicatable. Plus, that's low end monster damage there, a lot of them roll d8's or d10's. But even with these d6's he would do 22 damage + the 5.5d6, which means about 41 on average and 55 max. Again, that's in the neighborhood of a third of the Cleric's hitpoints, which is a really hard hit. That, followed by regular attack, cold possibly drop a slightly bloodied cleric.
BTW, that's something else that's an issue here. PC's roll for initiative, but monsters essentially all go together (unless you roll separately each of them, but I don't believe that this is the norm). This gives the monsters a chance to be much more dangerous because of multiple attack happening before the party can react. In the above example of the Cleric? Say he gets hit by a crit, and then 2 other monsters near the Cleric still have to take their turns. What, are you
not going to have them attack the Cleric? Well, if you do, chances are that they'll hit because Epic monsters have some really big bonuses. Even if we assume the 50% rule then at least 1 will hit, which means that he'll do an average of 17 damage, max of 22 (2d6+10, remember). So, added to the crit that's an average of 58 damage, with a max of 77. That's a 25 HP game just between the mid and high range, which is a lot of vaiability. A couple good d6 rolls and suddenly the Cleric will be down. Even the average is enough to drop a Cleric that's just 1 attack below bloodied.