SRD:Zone of Animation
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Zone of Animation [Divine][Epic]
The character can use a rebuke or command undead attempt to animate corpses within range of his or her rebuke or command attempt. The character animates a total number of HD of undead equal to the number of undead that would be commanded by the character’s result (though the character can’t animate more undead than there are available corpses within range). The character can’t animate more undead with any single attempt than the maximum number he or she can command (including any undead already under his or her command). These undead are automatically under the character’s command, though his or her normal limit of commanded undead still applies. If the corpses are relatively fresh, the animated undead are zombies. Otherwise, they are skeletons.