In 14.2.2 the phrase: * Rep(M)* means M occurrences of nil, empty, normal or absent representation. These are optional occurrences so default rules do not apply for empty representations. Begs the question of what happens if the empty representation is not the same as absent representation due to initiators and/or terminators being required by emptyValueDelimiterPolicy. If the empty representation is found, what would a Parser do? These are optional, so defaulting is not applicable. Treat it as "absent" is one possibility, Treat it as "normal" which is likely to result in a parse error, is another. Mike Beckerle | OGF DFDL Workgroup Co-Chair | Tresys Technology | www.tresys.com Please note: Contributions to the DFDL Workgroup's email discussions are subject to the OGF Intellectual Property Policy <http://www.ogf.org/About/abt_policies.php>