Right now complex elements can be nillable, but we have this ad-hoc restriction that says the nilValue can only be %ES;.
The rationale for this is unclear to me. Can we review what the rationale for this restriction was? Does anyone recall?
We have a format where the literal nil value for the complex type wants to be "%WSP*;-%WSP*;" that is, a hyphen, but with surrounding whitespace absorbed.
We can model this a different way, but the natural thing to do is to model it as suggested.
(This also just happens to run on Daffodil - because we're not detecting this ad-hoc restriction - a bug)