Recently observed about the DFDL Spec 12.3, in a discussion about what can have lengthUnits 'bits'.

Note that this also adds that it's not allowed for representation="binary". So we can have lengthUnits="bits" for these types when representation="text", we should ensure we still allow that.

I think this was not intended. I.e., I think the wording should be clarified to disallow lengthUnits bits regardless of representation for the types where it is currently disallowed. 

Mike Beckerle 
Apache Daffodil PMC | daffodil.apache.org
OGF DFDL Workgroup Co-Chair | www.ogf.org/ogf/doku.php/standards/dfdl/dfdl
Owl Cyber Defense | www.owlcyberdefense.com