>I believe, this is a critical shortcoming in DOM (i.e., not able to
>create/modify internal DTD subset in standard DOM). Is there some
>place, where I can ask for this functionality in DOM?

DOM Level 3 considered adding DTD/schema support, but in the end the
validation module was all that survived as consensus on what might actually
be general enough to be worth standardizing. See
http://www.w3.org/TR/2004/REC-DOM-Level-3-Val-20040127/

I don't think it's likely that the W3C will invest further effort,
especially since you're specifically asking for DTDs and the W3C wants to
see folks move to Schemas (for multiple reasons, most notably namespaces).

The only approach that I think would have even a slight chance of being
accepted would be for you to get an independent group together, rigorously
hammer out a proposed set of extensions to the DOM (keeping in mind all the
issues of abstraction and minimality and interoperability that have
characterized the DOM so far), submit it to the W3C as a Note, and hope
that if you've done an absolutely brilliant job someone says "Yeah, that
looks like it's worth standardizing." That's more likely to happen if your
solution is informed by the past discussion of this problem and if it
somehow manages to address schemas within the same abstractions (which, as
noted above, is a very difficult problem to address cleanly since the two
are really not fully commensurate).

In other words: It's likely to take a year's committee work and a minor
miracle. If it isn't worth that much investment and risk to you, the simple
answer is "no, you're going to have to go with a non-standardized API."

Sorry to bear bad news -- but I was there for part of the discussion, and
I've got some idea of just how hard it's going to be to produce something
everyone will accept.

______________________________________
"... Three things see no end: A loop with exit code done wrong,
A semaphore untested, And the change that comes along. ..."
  -- "Threes" Rev 1.1 - Duane Elms / Leslie Fish
(http://www.ovff.org/pegasus/songs/threes-rev-11.html)

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