I bet on also need to define PDF as a NOTATION, obviously the "| PDF" allows to extend the attribute list but doesn't define it as a notation. Try to add
<!NOTATION PIC SYSTEM "PIC">
in the internal subset of the document, and see if this validates, I bet it's the problem :-)
<!ENTITY % local.notation.class "| PDF"> <!NOTATION PDF SYSTEM "PDF">
works. (PDF not PIC)
Tobi
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