That really sucks. I'm visually impaired and many members of my family are/were blind. I think accessibility is really important, but it's so painful to me to feel like people's limited energy is being directed towards performative measures, useless rituals, vanity metrics, etc.
Nobody has infinite energy, and disabled people don't have infinite social capital. It's a shame when energy from that shared pool gets spent on things that don't really impact meeting people's access needs.
And the other thing is that everyone's access needs are different. It can certainly be useful to try to set a baseline or propagate common guidance. But the most important thing, especially in a university setting, is for instructors to be flexible and responsive and for classes (and non-teaching workloads) to be structured in a way (e.g., small enough) that supports that.
I think metrics like "100% accessible" might even be dangerous. It makes it easy for able-bodied people who aren't in direct contact with disabled stakeholders to pat themselves on the back without actually knowing what's going on.
Bleh. Good luck doing right by your disabled students and disabled colleagues, and good luck resisting the bullshit.
I was only a lowly TA so I saw these issues from afar, but I would add that, on a more optimistic note, I don't think I've ever met an instructor who wouldn't do whatever he or she had to do to support someone with special needs. As you suggested, metrics do not tell the whole story and certainly metrics for the sake of metrics are not helpful and may in fact be dangerous.
That said there is certainly a lot more work that needs to be done in this area. Hopefully these regulations over time bring out practical positive change. Time will tell.