Simple RAW Thread for 3.5 #32: More Seasons than the Simpsons

[Andezzar]

Re: 128

While the ghost template does not add any attacks they do have touch attacks through being incorporeal:

An incorporeal creature’s attacks pass through (ignore) natural armor, armor, and shields, although deflection bonuses and force effects (such as mage armor) work normally against it.

If that isn't an incorporeal touch attack I do not know what is.

As quoted above Draining touch does not add an attack, it adds an effect to existing attacks.