AuraSeer said:
Touch Attack
Touch attacks come in two types: melee touch attacks and ranged touch attacks. A character can score critical hits with either type of attack. A character's opponent's AC against a touch attack does not include any armor bonus, shield bonus, or natural armor bonus. The target's size modifier, Dexterity modifier, and deflection bonus (if any) all apply normally.
The two types appear to be distinct from one another and in fact the only two spells that do not signify whether it is a melee or a ranged touch attack in the SRD are Mass Heal and Harm. Another fact that causes confusion with this spell other then it does not specify which touch attack it is using is that it doesn’t follow the way touch attack work in other instances.
I also could not find any spells that did not count extra touch attacks in addition to the one for the subject (singular in all instances)* of the spell as anything but attack actions.
What it appears to be is an attempt to give the undead in the area of effect a "saving throw" with out really thinking through the rest of the mechanics of the game.
Personally I don’t think heal or harm were well though out to begin with.
Edit: *Except flame arrow which I just remembered and looked at. So this is not neccesarily correct.
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