The text states that the lower sections are completely submerged, yet the characters only encounter water halfway down the steps to Area 19. The steps appear to go down about 10', which leads me to believe that the water is about 5' deep. Am I missing something?
Also, if those rooms are completely submerged, there's no way in hell a character could hold their breath the whole time or come up for air (without retreating back to the steps). How have your groups gotten through it? Am I completely off?
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This has come up in the past. I believe the fix was to extend the stairs down into the submerged section, as the underwater portion of the encounter is what makes it both a challenge and an interesting fight.
<b>EDIT: </b>Here's a link to the original question. Enjoy!
http://paizo.com/paizo/messageboards/dungeon/ageOfWorms/dMQuestionsAboutThe WhisperingCairn