Una rote:

These <freeform comments> are natural-language paragraphs embedded in otherwise fully parsable data, which is the opposite of Kevin's case above. And much easier to handle, I think.

That is an intersting perspecitve, and probably right... but although coming from different directions, is there a real difference in the final result? Both end up as mixed content of structured (and parsable character data interspersed with free form text...

I put interesting data in the comments for an extremely important reason: I know I don't have enough data to represent the probable diversity in the taxon (the item), and I do not want to understate the diversity. Better to leave the character coded as unknown, but record the data. At some point in the future, the data can be moved from the comments to where it belongs.

Absolutely... and isn't this the holy grail we are seeking in this descriptive data standard? I am quite sure that the model we come up with with have a structured place for this freeform and comment stuff... to do anything less will be to admit failure...

jim