I've implemented a workaround for the problem of NVDL: I'm now splitting the Gazetteer into two separate temporary files, one TEI and one XHTML5, and validating each separately, then deleting them. It's the best approach I can devise for the moment. Once I did that, I found that the XHTML5 was not in Unicode NFC; I've now set up the two gazetteer-handling XSLTs to do that, but it reminds me that we should try to get NFC enforced throughout the data collection if we can.