Glenns' quote:
  A system declaration must meet the same syntax requirements
  as an SGML declaration with respect to the concrete syntax used,
  data characters allowed, etc.
 
Also, in Goldfarb p452:
  NOTE--It is recognized that the recipient of a document must be able
  to translate it to his system character set before the document can
  be processed by machine. There are two basic approaches to
  communicating this information.
      . . .
    As the last not implies, the document character set parameter is
  ignored by the SGML parser because the document is already in the
  document character set. The parameter is intended for a human to
  read in printed form, in order to determine how to translate an
  incoming document to the local system character set.
The actual translation process from a document character set to the
system character set is not defined, so we have 2 ways to interpret
these notes: 
  1) That all characters in the document must also be available to the
     system, and a simple one-to-one translation is performed.
  2) That the translation process can perform arbitrary translations.
Also, the system representation is undefined, providing another grey
area.