I was being conservative in my estimates, and assuming that other players aren't optimizing. 8 RHD and +0 LA would be fine in my books.
Yeah, that blood drain might be worth more for LA if you didn't have to pin and maintain the pin to even use. That alone makes it nearly worthless to anyone not maxing out grappling or making a paralysis-based caster. But I'm sure you realize that, too.
Yeah, immediately after I saw it was poison based, I knew it was pretty bad.
Told the player that if the DM didn't convert it in a decent manner, to just walk away from the race altogether.