I admit that I'm not against the idea of going through the SRD and setting spell levels and such.
However, I like the idea of using a formula, and I'd like to stick with it, if possible.
For one, the formula - as it stands - indicates that blue spells are harder to use than normal magic, that they stand outside the standard magic architecture. The fact that they require the expenditure of so many spell levels worth of spell slots, quite often which is higher than 9th-level total, is also indicative of this. It's not just mechanical at that point, it's also flavor.
Also, if new monsters are added, be it by DMs or by the LEW community as a whole, it means that I (or someone else) doesn't have to go through it and determine what level the spell is - it's already done, with the formula, and it requires almost no work to determine how it fits in the formulaic system.
However, if everybody really thinks that it would work out better if I went through the SRD and gave every Su and learnable Sp ability a spell level, then I suppose that's what I'll do.
Really, right now, the only sticking point with the formulaic system is Quickness, and other abilities like it - abilities used by low-CR creatures that would be high-level spells if they were part of the normal spell architecture. "Standard" blue spells - Su abilities that are pretty even with their monster's CR - don't pose an issue; Sp abilities that replicate spells and list a CL are easy to deal with using the formula I posted earlier (CL - Learner level).
I also figured today that, if a blue spell would require an item that is not part of the monster's natural anatomy (a lantern archon's trumpet, a grig's otto's irresistable dance), then the learner cannot use the spell. That prevents some broken things from occuring, as well as making it fit the flavor of the class - the learner shouldn't be able to replicate what a creature can do with a piece of equipment, the learner is learning what the monster can do innately.
I have even considered the possibility of needing to set some monster abilities with an arbitrary spell slot cost - an idea I'm not particularly fond of, but I'd do it, if the rest of the system worked. And I honestly think it does.
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Basically, it comes down to two choices...
1) Use the formulaic system as it stands, possibly with a degree of modification. Put in the appropriate restrictions on what can and cannot be learned, then set the spell slot cost of blue spells which would be broken using the system.
This has the advantage of being easily adapted to new monsters, as well as keeping the flavor of the learner through the mechanics; however, it will be slightly unwieldy in comparison to the simple direct-to-level system, and has to set some spell slot costs arbitrarily.
2) Go through the SRD and assign a spell level to each Su and learnable Sp ability. This is the easiest way to solve the broken spell problems.
This has the advantage of everything being spelled out, no questions asked, and also allows it to work nicely within the spell system as it stands; however, it means that any new monster will have to have its abilities set with blue spells and how they function as blue spells, as well as a loss of a degree of flavor.