> Can anyone also confirm whether, for a document instance without a DTD,
> I can have free-standing <!ENTITY...> declarations. I.e. entity
> declarations that are not inside a Doctype declaration?
No, you can't. Declarations other than DOCTYPE declarations can only
occur within a DOCTYPE declaration (the internal subset) or within an
external entity referred to from a DOCTYPE declaration (the external subset).
The DTD (document type definition) is precisely the set of declarations,
so talking of declarations in a document instance "without a DTD" is a
contradiction in terms.
-- John Cowan cowan@ccil.org e'osai ko sarji la lojban.