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I've skimmed over the request; I think it comes down to how, exactly, ACS is legally defined, and what features are normally mandated to make it compliant.
I'll go with "e-ink ereaders should not be required to provide subtitles for videos." I'm much less sanguine about "should not be required to provide text-to-speech options for email;" I know several people who use their e-ink readers for gmail. (And providing TTS for email and their browsers would push them in the direction of supplying speech-based navigation menus, which is one of the stumbling blocks keeping them out of public schools.)
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