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Even on the same map template, there can be a significant variation. For example, a Devil's Lair might be guarded by anything from a cheap group like, say, a group of Gnomes, to a large group of Basilisks. The reason is unknown.
I'll venture to suggest that the strength of the guard might depend not only on the level of the creature but also on its value (i.e., the lairs of Wood and Earth Elementals will differ in terms of their guard).