4.5 paragraph 3 is still problematic, saying "Processing instructions can be ignored by processors because they are not part of a document's character data." On the contrary: Section 2.6 of the XML Recommendation says
# PIs are not part of the document's character data, but must be # passed through to the application.
This is actually a stronger requirement than is made for elements! If you want to recommend that PIs not be used, you need to find a different rationale.