Sorry, my pet peeve
"Originally e-mailed by Andy Collins on November 4, 2003:
I don't know why the FAQ disagrees with the ELH. (It also seems to
disagree with the epic rules presented in version 3.5 of the DMG.)
Personally, I'd stick with the actual rules rather than the FAQ, but that
call is up to the DM."
OMG! The fact that he didn't even understand the issue just clinches my opinion of him. The truth is that several sources describe the process of epic monster advancement differently. There are many inconsistencies between and within ELH, Savage Species, the 3.5 DMG, and the FAQ. WotC clearly have not made up their collective minds about this matter. The fact that the FAQ references a passage that it soundly contradicts illustrates how poorly WotC understands the issue. Savage Species, I believe, uses the HD progression into epic benefits rather than the ECL progression. Personally I believe that is the only consistent way to apply the epic rules.
According to the 3.5 DMG, a monster that does not have a Level adjustment cannot gain epic level benefits, or rather there are no epic-level rules given for monsters that do not have character levels. This answers the question of this thread.
Of course, the example given in the 3.5 DMG p. 209 for epic monster advancement is a problematic one. According to the example, the 3 HD bugbear Frt14/Blackguard 3 has an ECL of 22 and thus gains an epic attack and save bonus.
Problem one is that the character actually has an ECL of 21, since the level adjustment for a bugbear is +1, not +2.
The major problem is that the character has 20 total HD but it apparently uses the Epic advancement rules for its last two HD of advancement rather than the normal advancement for its class. This is quite different than the rules of advancement for characters without level adjustments. In fact, it leads to this character having a lower BAB than an equivalent character with no level adjustment.
If the character's most recent two levels were in blackguard, than normally he would gain the following bonuses for Blackguard levels 2 and 3: BAB +2, Fort +1, Ref +1, Will +1. Using the Epic progression, he would instead get: BAB +1, Fort +1, Ref +1, Will +1. His BAB would actually be lower than that of an equivalent character without a LA.
The FAQ manner of epic progression is a consistent way to handle epic progression for all characters, regardless of LA. Although the 3.5 epic monster character rules are more internally consistent than those in the ELH, they still create separate systems of epic-level advancement for creatures with different level adjustments. Additionally the FAQ manner of epic-level monster advancement opens the way for high HD monsters to have Epic-level feats.