Can't it just be part of acs-subsite? It seems fundamental and acs-subsite is self-aware, so to speak. Thus far that's worked fine for me with my simple little ad_return_exception_template code. My example db-error.adp template's in acs-subsite/www/shared, not a great place for it. perhaps acs-subsite/www/error-templates or something like that?
And it would make sense for parameters that might modify behavior on errors to be set at the subsite level along with other look-and-feel parameters, rather than off in another package.
If there are good reasons for having a new error package we should, of course, but my first thoughts are that this should just be a acs-subsite enhancement.