Cleon
Legend
The whirlwind ends if the tornado loses sight of it.
Oops! Methink my copy-and-replace went slightly awry! Should be "The tornado ends if the firelord loses sight of it."
ok so recharge 4-6 - and.....if CR 19 is approx 119 damage/round and this has some area of effect...55 (10d10)?
That's way too much.
Remember, the tornado lasts as long as the firelord can Concentrate, and it can perform actions while concentrating like attacks or casting non-concentration spells. As written, it only needs to spend an action to move the tornado, it can keep it stationary and roast whatever victims are trapped inside it without using an action.
So on subsequent rounds it could be doing 55 (10d10) from a fire tornado plus 66 (12d10) from an incinerating inferno plus whatever damage it can scrape from its Bonus, Reaction and Legendary Actions.
That said, I did want this ability to do hefty damage, so we could either time limit it more severely, like "Recharges On A Short Rest" or tweak it so maintaining it requires an Action.
Like so:
Tornado of Flames #2. A 10-foot-radius, 60-foot-tall cylinder of swirling flames magically forms on a point the efreeti firelord can see within 120 feet of it. The fiery tornado lasts as long as the firelord spends its action each turn maintaining it, which requires concentration (as if concentrating on a spell). A creature takes ## (#d#) fire damage, or half as much damage on a successful DC 22 Dexterity save, when it enters the tornado for the first time on a turn or ends its turn within the tornado. Any creature but the firelord that enters the tornado must succeed on a DC 22 Strength saving throw or be restrained by it. The firelord can move the tornado up to 60 feet as a bonus? action, and creatures restrained by the tornado move with it. The tornado ends if the firelord loses sight of it.
Tornado of Flames #2. A 10-foot-radius, 60-foot-tall cylinder of swirling flames magically forms on a point the efreeti firelord can see within 120 feet of it. The fiery tornado lasts as long as the firelord spends its action each turn maintaining it. A creature takes ## (#d#) fire damage, or half as much damage on a successful DC 22 Dexterity save, when it enters the tornado for the first time on a turn or ends its turn within the tornado. Any creature but the firelord that enters the tornado must succeed on a DC 22 Strength saving throw or be restrained by it. The firelord can move the tornado up to 60 feet as a bonus? action, and creatures restrained by the tornado move with it. The tornado ends if the firelord loses sight of it.