err, yeah, 2d20 is more like 6d6, but with a flatter curve, so it's "more random." kinda fits into a more-chaos flavor
6d6 for a second-level area spell? wtf?
among other things, I allow neither 3.0 sources, nor the BoED/BoVD set, so there's no way this spell makes it in. I might allow it...