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One PC is a darfellan from Stormwrack that's taken levels in the class dread necromancer from Heroes of Horror. A darfellan has a natural bite attack that can be used as a secondary natural weapon attack alongside weapon attacks. The player asked if his PC can deliver the charnel touch with his PC's bite, foregoing the bite damage to deal the charnel touch damage.

I told him I didn't see why not, but thought I'd check if there were an official rule somewhere.

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    \$\begingroup\$ I edited this question to make it specific to the supernatural ability charnel touch since that was the question's primary concern. If touch attacks can ever be substituted for natural attacks seemed overwhelming. (It's 3.5 so there's always an exception somewhere!) I hope this increased specificity is okay. \$\endgroup\$ – Hey I Can Chan Aug 12 '18 at 5:10
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So, the rules here are a bit of a mess.

About hands...

First, we have the description in charnel touch that describes the negative energy concentrating in the dread necromancer’s hands—but that’s just fluff. Descriptive statements like this are sprinkled throughout 3.5e, and are consistently only meant as just that, description—not proscriptive rules requirements. This has come up a few times here, if you want to see some other examples—there are many more. So that should be ignored.

About touching...

Second, we have the question of how supernatural touch attacks are delivered. The rules for touch attacks are in the section all about spells, specifically, and the rules for “touch spells in combat.” They don’t mention non-spell touch attacks much at all. So the question is, do these rules apply to supernatural touch attacks—and if not, what rules do apply to them? Simply for sheer lack of any other rules to fall back on, I would argue that these rules must apply to non-spell touch attacks.

Relevantly, one of those rules mentions natural weapons:

Holding the Charge

If you don’t discharge the spell in the round when you cast the spell, you can hold the discharge of the spell (hold the charge) indefinitely. [...] Alternatively, you may make a normal unarmed attack (or an attack with a natural weapon) while holding a charge. [...] If the attack hits, you deal normal damage for your unarmed attack or natural weapon and the spell discharges. If the attack misses, you are still holding the charge.

So with holding the charge, not only can the darfellan use their bite to deliver charnel touch, they can actually include their bite damage along with it, if they target regular AC instead of touch AC.

Complete Arcane page 73 goes into somewhat more detail on this... except it fails to mention natural attacks, and focuses solely on unarmed strikes (while again focusing solely on touch spells):

Improved Unarmed Strike: You can add the damage of your unarmed strike to the damage of a touch spell by delivering the spell as a regular melee attack instead of a melee touch attack. The defender gets the full benefit of armor and shield, but if the attack hits, the unarmed strike deals normal damage over and above any damage the spell does as it is discharged. If the unarmed strike misses, then the spell is not discharged.

Again, I would argue that this is specific to unarmed strikes for much the same reason I suspect that the touch-attack rules all focus on spells: Player’s Handbook and Complete Arcane are player-focused books. Spells are what player characters, by and large, actually have. At this point in 3.5e’s publication history, the only supernatural touch attacks offered by classes were the paladin’s lay on hands and the blackguard’s deadly touch—not a whole lot. Likewise, barring wild shape or polymorph effects, the only option for natural attacks for players were found level-adjusted creatures in Monster Manual. So I think they just stuck to the most-expected cases (spells, unarmed strikes) for simplicity/word count. I cannot back this suspicion up with any hard evidence, however.

About actions...

Thirdly, we have a question of how charnel touch interacts with the action economy. The default rule for supernatural abilities is that they take a standard action “unless otherwise specified.” In the charnel touch description, we have “At will, but no more than once per round, she can make a melee touch attack,” which makes absolutely no sense as a restriction if it takes a standard action anyway. There are a very few ways to get a second standard action in a round, but none of them are natively available to a dread necromancer or found in Heroes of Horror. In other words, I have always read this description as specifying that charnel touch, unlike other supernatural abilities, does not use a standard action, but rather can simply be used in place of any attack the dread necromancer would otherwise get to make.

That would include the attack the darfellan could have used to bite.

Conclusion

A darfellan dread necromancer could choose to deliver a charnel touch attack instead of, or along with, his bite attack. If he chooses to deliver it with the bite, it must hit the target’s regular AC, rather than its touch AC, and on a critical hit only the bite damage, not the charnel touch damage, is doubled. If he chooses to deliver it as a touch instead of the bite, then he gets to target touch AC, but misses out on bite damage. (For most dread necromancers, against most targets, the expected damage is higher with the touch attack, because their chance to hit is so much higher and the bite damage itself doesn’t add so much.)

In both cases, any penalties the bite attack takes, for example for being a secondary attack (if the darfellan had also attacked with weapons), would also apply to the touch attack.

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  • \$\begingroup\$ If it doesn't specify the action to make use of the supernatural ability as anything different from a standard action, it is a standard action regardless of what it can be inferred. Just because is rare, it isn't impossible to make more than one standard action in a turn. You're just assuming without anything concrete and that's not how answers in RPGSE works according to another comment of yours. \$\endgroup\$ – Aguinaldo Silvestre Aug 12 '18 at 14:15
  • \$\begingroup\$ @AguinaldoSilvestre I feel I have backed up my claims. If you disagree, you are welcome to downvote, as I assume you have. \$\endgroup\$ – KRyan Aug 12 '18 at 14:23
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Despite the supernatural ability charnel touch saying that the ability's negative energy is "concentrat[ed] in her hands" (Heroes of Horror 86), this DM would allow a creature to employ charnel touch with any reasonable body part. That is, this DM wouldn't forbid a creature from using the charnel touch ability just because the dread necromancer class's author didn't consider the fact that a handless creature may want to become a dread necromancer!

(A dark naga (Monster Manual 191—2), for instance, should really take levels in sorcerer, but it should also be able to use all its class abilities were it to take instead levels in dread necromancer! By the way, this DM has always assumed this is the case, viewing it as a reasonable extension of the Monster Manual on Spells that says, "A spellcasting creature that lacks hands or arms can provide any somatic component a spell might require by moving its body" (315).)

Thus this DM would allow a darfellan (Stormwrack 37—9) dread necromancer that forgoes its normal bite damage to deliver its charnel touch with its bite.

However, both the Player's Handbook and the Monster Manual agree that using a supernatural ability is a standard action: "Using a supernatural ability (such as a cleric’s turn or rebuke undead ability) is usually a standard action (unless defined otherwise by the ability’s description)" (PH 142), and, "Using a supernatural ability is a standard action unless noted otherwise" (MM 315).

Because the supernatural ability charnel touch does not say otherwise, the charnel touch ability can't usually be used in addition to other attacks during a full attack—instead, a typical dread necromancer must use the charnel touch ability alone, each use of the charnel touch ability taking its own standard action. This means a typical darfellan dread necromancer cannot, for example, take the full attack action to make one or more attacks with its scythe and use the ability charnel touch, even by forgoing its bite damage.

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  • \$\begingroup\$ @KRyan …And you did argue so,—and elegantly,—but I still disagree. The entire Monster Manual quotation goes like this: "Using a supernatural ability is a standard action unless noted otherwise. Supernatural abilities may have a use limit or be usable at will, just like spell-like abilities" (315). So, to me, with that full quotation in mind, an ability's really gotta say more than at will, but no more than once per round to convince me that a supernatural ability is usable as anything less than a standard action. \$\endgroup\$ – Hey I Can Chan Aug 12 '18 at 13:41
  • \$\begingroup\$ Yeah sorry, comment came first. I’ll delete and leave my answer to make my case. \$\endgroup\$ – KRyan Aug 12 '18 at 14:22
  • \$\begingroup\$ @KRyan It's cool. I appreciate the explanation for the downvote (even though I kind of guessed what I got it for). \$\endgroup\$ – Hey I Can Chan Aug 12 '18 at 14:24
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RAW, he can't.

Charnel Touch (Su): Negative energy flows through a dread necromancer’s body, concentrating in her hands. At will, but no more than once per round, she can make a melee touch attack against a living foe that deals 1d8 points of damage, +1 per four class levels. This touch heals undead creatures, restoring 1 hit point per touch, +1 per four class levels.

As I emphasized, the supernatural ability clearly says the energy is concentrated in the character hands, making it impossible to do that with a bite attack. In this particular case, it might have been intended the use of hands to ensure someone isn't using it as a secondary natural attack to increase the number of attacks per round with an extra touch attack while using their hands to something else (spellcasting, shield, two-handed weapon).

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    \$\begingroup\$ 3.5e simply does not intend such descriptive statements as proscriptive requirements. This is a consistent facet of the system, and makes this reading of the ability simply wrong. Many, many things about the system break down if you try to read things this way consistently. \$\endgroup\$ – KRyan Aug 12 '18 at 12:18

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