Start a design discussion on how to achieve this, Ben. In particular, we should be thinking about ways to make things like integration with scoping and groups happen in default ways automatically, a way to register with the general comments module that creates the appropriate table inits and delete triggers with no need to hand-edit general-comments.sql, and should generalize access security (aD seems to be moving in this direction, I've not checked 3.1+ so this may be a red-herring).
Let's build a list of services that the ACS framework should provide to modules.
Since Tcl is not an ideal language for this, we should then think about how to cleanly provide the framework. I should probably look at Tcl8 sometime to see if there's help there. Of course, it craps with AOLserver3 at the moment but that presumably will get fixed.