One interesting thing that Jin said, and I believe it is probably true, is that most of the ACS is the SQL -- the Tcl framework is just plumbing that connects it to the web page.
If we assume for the moment that this is true, then it seems like a logical plan would be to develop our own "modular" framework (perhaps based on aD's templating effort) that would abstract the DB interface, and provide a bug-compatible ACS. When we "port" from one version to the other, we would mainly be concerned with "porting" the SQL used by the forms. We would then need to update our templates or "plumbing" to support it.
This is similar to the task of porting a Motif-based program to GTK, for example. The underlying model is the same, but you might have to implement slightly different routines to match the "API" of the displaying system.