I was assigned by the Internationalization Directorate to do a review of this document with a specific eye on internationalization and also a specific request from AD to look at section 10.

I would like to point out that in some cases, the spec seem to provide a choice for the implementor/deposit provider to use something else than UTF-8 for the non-ascii encoding. For example, section 4.6.2.1. provides a choice of encoding for csv files: "encoding  Defines the encoding of the CSV file with the default encoding of "UTF-8". Moreover, section 10 talks about UTF-8 and UTF-16 and recommends UTF-8 instead of making it mandatory. At the same time, there are multiple fields in this spec that are defined as UTF-8. Therefore, it would be appropriate and much less prone to interoperability problems to make UTF-8 the only encoding possible, specially given that most protocols, data payloads and software librairies are using UTF-8 encoding. If the authors agree, then section 10 and 4.6.2.1 could be revised, and probably adding a paragraph in section 1 or 4 that states the only possible encoding is UTF-8 for both CSV and XML files.

Section 9.14 schema has a comment on ACE name field. Wonder if A-label would be more appropriate.

Section 5.6.2.1.1. While in other parts of the spec, the encoding was clearly identified as UTF-8, the definition of "<rdeCsv:fUName>  Name of the NNDN in Unicode character set for the <csvNNDN:fAName> field element." does not state any. Might want to say it clearly as UTF-8 like others.