Can Cold Spell Specialization affect Shivering Touch?


I have a player trying to apply the benefits of Cold Spell Specialization to the spell Shivering Touch.

Shivering Touch:

On a successful melee touch attack, you instantly suck the heat from the target’s body, rendering it numb. The target takes 3d6 points of Dexterity damage. Creatures with the cold subtype are immune to the effects of shivering touch.

Cold Spell Specialization:

In cold areas (temperature at or below 40° F), you gain a +1 bonus per die to any dice rolled to determine damage caused by cold spells you cast. In areas of extreme cold (below -20° F), the damage bonus increases to +2 per die.

I told the player that this doesn’t work for 2 reasons:

  1. The spell has a duration, and so the Dex damage isn’t really damage, it’s really a penalty, and thus wouldn’t apply.

    Reasoning:

    1. Ability damage is persistent, being removed at 1 point per day, not all being removed in 1 round per caster level.
    2. Ray of Enfeeblement was originally worded very similarly, and was later errata’d to being a penalty instead.
  2. Unless specified otherwise, "damage" refers to hit point damage, not any other kind of damage that the player might try to twist in.

I was coming up with these reasons on the fly based on because I couldn’t find the RAW that prevented the use of this in a timely manner.

I would prefer to remain in the RAW than to create either reasoning as a house rule that could have later unforeseen repercussions. Can someone point out where this is specified, or was it something that was assumed as carryover from previous editions?