Robert, thank you for your questions!
This is a tricky issue and you have certainly focused on important factors so far. Here is the advice from our tactile graphics (TG) experts:
First, yes. Guidelines & Standards for Tactile Graphics (GSTG) 5.8.1.2 only applies to keys and not to labels in the actual TG. We know this because the title of that section in the GSTG is "5.8.1 Keying Techniques ..."
Second, we would not add the grade 1 indicator (dots 56) to the labels starting with lowercase a-d because in the TGs you show us, the lowercase letters are not standing along. They are not standing alone because the letter is in contact with the two-cell degree sign.
For future reference, when there is limited space for inserting labels, Guidelines for Technical Material (GTM) 4.4.2 allow: "When labelling angles, the degree sign could be omitted. Include a transcriber's note."
Also following GTM 4.4.2, "[w]hen labelling points, lines etc. with single letters, these can be consistently shown as two cells by omitting the grade 1 indicator for all capital letters and including it for all lowercase letters including a, i and o.
However, in your current examples this will not be necessary because you have lots of space for the labels.