The Allow operations in the default httpd.conf do not have <IfModule mod_access.c> or have mod_access.c statically linked into the server. The current compilation of httpd seems to assume that mod_access is optional, while the default httpd.conf seems to assume that it's mandatory, I believe that for consistency one of these needs to change. It's probably best to have it compiled in, almost no-one would want to not have it, and needless use of modules wastes some memory and load time.
There is no mod_access in 2.2; see http://httpd.apache.org/docs/2.2/upgrading.html All modules built as DSOs are by definition optional; you can write valid configurations which don't use them; building them into all httpd binaries shipped would waste space (installed disk space and package space).