Stonesinger: Above average natural AC for 9 RHD, and net +32 abilities are just below par-acceptable on about 8 RHD. DR 5/Magic means its natural attacks bypass DR/Magic, so you can scrimp on the necklace for a while. 7 natural attacks with average base damage have potential, while the decent poison and SLAs are solid.

However, this thing loses 3 points of BAB and has 9 levels of 2 poor saves and 2+Int skills, so it compares poorly to most natural attack builds that got their extra attacks through PRCs or quality templates. It is also rather slow, even with the extra movement modes-its base land and climb speed are 10-20 feet per round slower than average for such a multi-ped, but the burrow speed alleviates that somewhat. And the usual disclaimer about no obvious hands and odd body slots.

Overall, I am leaning towards an almost playable LA -0. I think you could shave as little as a single RHD to get something on par, albeit with the usual DM caveat about critters with no obvious manipulator limbs.