Re: Production 21 (and others)

Sean McGrath writes:
> I totally agree. Credibility amongst implementors is at stake.
> If comments are complex enough in regexp to warrant a BNF grammar 
> instead then I say lets give'em a BNF.

More than that: one FAQ from CS SGML-non-initiates (read: implementors)
is always "Where's the BNF? "Why do we have to use this weird syntax?"