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Documenting DTD's

I just spent a half hour listening to our docs/help person complain about
the uselessness of generating documents containing english language
descriptions of elements defined in DTDs.  As soon as she writes the stuff
it's obsolete or vague, and why should she be a middlewoman adding little
additional real value between the DTD writer and the DTD consumer, etc.

So, two questions for the list: a) is there a javadoc-like standard for
adding comments to DTDs and a set of tools out there for extracting them
and, better, b) is there a tool out there that will read a DTD and produce a
decent picture of the elements and their relationships?  I'm sure there must
be something out there we could leverage before we roll our own...


PS And of course I'm interested in anyone's experience/thoughts on
generating and maintaining useful documentation for DTDs.