@Cstone: I had a quick look empirically and it is clear that we aren't sending failure emails for ACH at all (first time or later failures). This SK shows there are very few contacts with a failure email after a failed ACH recurring (but those are people with another recurring that isn't ACH and the email is related to that, so this confirms we aren't sending any).

It looks like this is because these ACH failures are processed through RefundQueueConsumerand we don't send failure emails from cancelRecurringOnChargeback(). Looks like we could add that send in there. I suppose we'd want to think about if any of the other payment methods we are dealing with in here would also merit failure emails.

Draft proposal for handling these