I think being “Earth Gliding” should provide some form of benefit over simply burrowing. Normal (not total) cover from adjacent foes who are not also earth gliding, for example. Otherwise the comparison/adaptation of underwater combat rules seems a very good basis.
Earth Glide (Ex):
When the creature burrows, it can pass through stone, dirt, or almost any other sort of earth except metal as easily as a fish swims through water. If protected against fire damage, it can even glide through lava. Its burrowing leaves behind no tunnel or hole, nor does it create any ripple or other sign of its presence. A move earth spell cast on an area containing the burrowing creature flings it back 30 feet, stunning it for 1 round unless it succeeds on a DC 15 Fortitude save.